COMMISSION STAFF WORKING DOCUMENT Accompanying the document 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  SWD(2026) 64 final  COMMISSION STAFF WORKING DOCUMENT   Accompanying the document 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  {COM(2026) 86 final}  
 
 
Table of Contents 
1. Introduction ............................................................................................................. 3 

1.1 Methodology .................................................................................................... 3 

1.2 Legal and policy context ...................................................................................... 5 

1.3 Regulation of professions ..................................................................................... 6 

1.4 Mobility of professionals ...................................................................................... 7 

2. General system of recognition ....................................................................................... 8 

3. Automatic recognition based on professional experience ..................................................... 18 

3.1 Annex IV professions ........................................................................................ 19 

3.2 Application procedure ....................................................................................... 20 

4. Automatic recognition based on minimum training requirements ........................................... 22 

4.1 Mobility in professions with harmonised minimum training requirements ......................... 22 

4.2 Application procedure ....................................................................................... 23 

4.3 Minimum training requirements ........................................................................... 26 

4.4 Annex V notifications ........................................................................................ 34 

5. Common training principles ........................................................................................ 36 

5.1 Common training frameworks ............................................................................. 36 

5.2 Common training tests ...................................................................................... 37 

6. European Professional Card ........................................................................................ 38 

6.1 Functioning and current use ................................................................................ 38 

6.2 Future implementation ...................................................................................... 41 

7. Temporary provision of services ................................................................................... 41 

7.1 Temporary and occasional activity ........................................................................ 42 

7.2 Prior checks ................................................................................................... 42 

7.3 Declaration and fees ......................................................................................... 43 

8. Administrative cooperation ......................................................................................... 44 

8.1 Alert mechanism ............................................................................................. 44 

8.2 Provision of information .................................................................................... 49 

9. Enforcement .......................................................................................................... 51 

9.1 Overview of transposition .................................................................................. 51 

9.2 Infringement batches of non-compliance with the Directive.......................................... 52 

9.3 Individual cases .............................................................................................. 55 

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10. Insights from professionals and businesses ................................................................... 56 

10.1 Individuals’ views ........................................................................................... 57 

10.2 The business perspective .................................................................................. 60 

Concluding remarks: Is Directive 2005/36/EC fit for purpose? ................................................... 61 

2 

 
 
 
1. Introduction    
This Staff Working Document accompanies the Implementation Report based on Article 60(2) of 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).1 It provides the analytical data and insights supporting 
the policy considerations expressed therein.  

The last implementation report was published by the Commission on 11 May 20202, together with an 
accompanying staff working document.3 That implementation report covered a period of 5 years (2014-
2019) and focused in particular on the new elements introduced with Directive 2013/55/EU, including the 
specific implementation issues referred to in the second subparagraph of Article 60(2) of the Directive, 
such  as  the  European  Professional  Card,  modernisation  of  the  knowledge,  skills  and  competences  for 
‘sectoral’ professions, the common training principles and the special upgrading programme for Romanian 
nurses. 

This  implementation  report  covers  the  period  2020-2024 with  the  aim  to identify gaps,  issues  and 
challenges related to the implementation of the Directive in the current policy context.    

1.1 Methodology 

The Implementation Report and this accompanying Staff Working Document have been prepared on the 
basis of desk research and targeted stakeholder consultations.  

Various  stakeholders  have  been  consulted,  including  the  Group  of  Experts  for  the  Recognition  of 
Professional Qualifications, national assistance centres, national authorities competent for recognition of 
qualifications, professional organisations, civil society organisations, social partners and individual citizens. 
The consultation involved the use of different sets of surveys: to members of the Group of Coordinators  
and  Assistance  centres  (replies  from  25  Member  States)4  and  EU  level  and  national  professional 
organisations5 (carried out in the period Q2-Q3 2024);  and to competent authorities responsible for a 

1 Directive 2005/36/EC of the European Parliament and of the Council of 7 September 2005 on the recognition of professional 
qualifications.   
2 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 certain new elements introduced by Directive 2013/55/EU of the European 
Parliament  and  of  the  Council  of  20  November  2013  amending  Directive  2005/36/EC  on  the  recognition  of  professional 
qualifications and Regulation (EU) No 1024/2012 on administrative cooperation through the Internal Market Information System 
('the IMI Regulation')  
3 Commission Staff Working Document Accompanying the document 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 certain 
new  elements  introduced  by  Directive  2013/55/EU  of  the  European  Parliament  and  of  the  Council  of  20  November  2013 
amending  Directive  2005/36/EC  on  the  recognition  of  professional  qualifications  and  Regulation  (EU)  No  1024/2012  on 
administrative cooperation through the Internal Market Information System ('the IMI Regulation')   
4 Austria, Belgium, Bulgaria, Croatia, Czech Republic, Denmark, Estonia, Finland, France, Germany, Hungary, Ireland, Italy, Latvia, 
Lithuania, Luxembourg, Malta, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, The Netherlands. 
5 Replies were received by 28 professional organisations. 

3 

 
 
 
number  of  professions  (replies  received  from  23  Member  States)6,  citizens,7  civil  society  and  partners 
(carried out in the period Q3 2024-Q1 2025).  

The table below provides an overview of the topics covered by the survey questions: 

Topics covered 

Subject matter covered by questions 

Automatic recognition for sectoral 
professions – recognition process   

Automatic recognition for sectoral 
professions – minimum training 
requirements 

General system of recognition – 
recognition process  

General system of recognition – 
compensation measures 

Qualification levels 

Automatic recognition based on 
common training principles 

Automatic recognition system based on 
professional experience under Annex IV 

Temporary service provision  

Application procedure and application fees for the 
professions of medical doctor and nurse, length of 
procedure, document requirements for the professions 
of medical doctor and nurse, administrative 
cooperation between Member States, number of staff 
needed in a Member State to process an application, 
functioning of notifications in the Internal Market 
Information System (IMI) in relation to Annex V 
qualifications, figures on sectoral health professions 
related to demand and shortages, existence of 
electronic systems for recognition procedure 
Adequacy of current minimum training requirements, 
effects of lowering minimum training requirements, 
effectiveness of amending minimum training 
requirements through delegated act 
Application fees, length of procedure, document 
requirements, administrative cooperation between 
Member States, access to electronic procedures. 
Functioning of compensation measures, length of 
adaptation period, waiting time to take aptitude test, 
definition of substantially different matters  
Application of the system of qualification levels under 
Article 11  
Candidate professions for common training 
frameworks, functioning of common training test for 
ski instructors, application fees, length of recognition 
procedure, document requirements 
Use of Annex IV, scope of Annex IV, length of 
procedure, application fees, document requirements, 
practical issues with proving practical experience 
Professions for which temporary service provision is 
used the most, fee related to written declaration, 

6 Austria, Belgium, Croatia, Czech Republic, Denmark, Estonia, Finland, France, Germany, Hungary, Ireland, Italy, Latvia, Lithuania, 
Malta, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, The Netherlands. 
7 More than 450 citizens who either obtained, or asked for the recognition of various professional qualifications in all EU Member 
States responded to a survey carried out by Commission services.  

4 

 
 
  
 
European Professional Card (EPC) 

Partial access  

Mobility from Member State in which 
profession is not regulated – one year 
of professional experience  

Alert mechanism  

Information provision and provision of 
statistics  

Continuous professional development 
for sectoral professions 

1.2 Legal and policy context 

identification of temporary service provision, art. 7(4) 
on prior checks 
Availability of information about EPC, extent of use of 
EPC, length of recognition procedure, application fees, 
challenges 
Use of partial access, challenges with partial access 
and improvements of use of partial access 
Existence of assistance in home Member State on 
issuing of document certifying 1 year of professional 
experience  

Definition/understanding of terms used in IMI module, 
handling of alerts, use of alerts in recognition 
procedure 
Sources of information and functioning of national 
contact points, whether registration system of all 
recognition decisions taken is in place in Member 
States 
How Member States have implemented continuous 
professional development in relation to sectoral 
professions 

Member States retain the competence to regulate access  to professions nationally, provided  that  they 
comply  with  EU  law  and  respect  principles  of  non-discrimination  and  proportionality.  As  a  result,  the 
regulatory requirements related to access to professions often differ from one country to another.  

Directive  2005/36/EC  facilitates  recognition  of  qualifications  for  both  self-employed  persons  and  for 
employees crossing borders within the Single Market. Broadly speaking, it provides for three main routes 
to recognition.  First,  certain professions  (doctor of medicine, nurse responsible for general care, dental 
practitioner, veterinary surgeon, midwife, pharmacist and architect) benefit from automatic recognition 
based on minimum training requirements. Second, there is automatic recognition based on professional 
experience for certain professions in the craft, commerce and industry sectors. Third, for all other cases, 
the so-called general system of recognition in principle applies. The latter obliges national authorities to 
compare qualifications and impose compensation measures (an aptitude test or adaptation period) only if 
substantial differences exist. 

The Directive underwent a major revision by means of the amending Directive 2013/55/EU8, which entered 
into force on 17 January 2014, and which had to be transposed by Member States by 18 January 2016. 
Directive  2013/55/EU  introduced,  among  other  things,  the  European  Professional  Card,  the  alert 
mechanism, the use of the Internal Market Information System, and the common training principles. The 
possibilities provided by these new elements are presented in detail below. 

8 https://eur-lex.europa.eu/eli/dir/2013/55/oj/eng  

5 

 
 
 
Directive 2005/36/EC contains empowerments for the Commission to adopt delegated and implementing 
acts  that  allow  for  regular  updates  and  increase  flexibility  of  this  legal  instrument.  For  example,  the 
Commission  has  used  the  delegated  powers  to  update  the  minimum  training  requirements  for  the 
professions  benefitting  from  automatic  recognition  to  keep  the  Directive  aligned  with  scientific  and 
technical developments in the respective fields. Such updates, based on detailed mapping presented in 
published studies per profession, have been adopted for the profession of nurse responsible for general 
care, dental practitioner, pharmacist and veterinary surgeon in 2024 and 2025.9 The Commission has also 
adopted  delegated  decisions  to  amend  Annex  V  to  the  Directive  as  regards  the  evidence  of  formal 
qualifications and titles of training courses.10 

To allow workers and businesses to fully exploit the potential of professional mobility in the Single Market, 
the Commission’s Union of Skills Communication announced a Skills Portability Initiative. The initiative will 
be  part  of  a  broader  skills  and  fair  labour  mobility  package  to  be  adopted  in  2026,  which  aims  at 
facilitating the exercise of the right of free movement and the free provision of services. This 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, simplification and better implementation of 
the labour mobility rules and practices, as also recommended by stakeholders participating in the recent 
Implementation Dialogue with EVP Mînzatu on fair labour mobility.  The report on the implementation of 
the Directive contributes to informing the Skills Portability Initiative by assessing the overall functioning of 
the  applicable  regulatory  framework  to  the recognition  of  professional  qualifications  in  the  context  of 
regulated  professions  and  by  identifying  key  implementation  gaps  and  potential  areas  for  further 
improvement. 

1.3 Regulation of professions  

Regulation of professions falls primarily under the competence of the Member States in compliance with 
EU law, notably the principle of proportionality, as established in the case law of the EU Court of Justice 
and the Directive (EU) 2018/958 on a proportionality test before adoption of new regulation of professions 
(‘the Proportionality Test Directive’)11. Within these limitations, they decide which professions are regulated, 
what  qualifications  are  required  for  those  wishing  to  access  and  exercise  them  and  which  authorities 
oversee access to and the exercise of the professions in question. 

While regulation is sometimes needed to safeguard public safety and quality of service, it can also create 
barriers  to  access  and  pursuit  of  professions.  The  Proportionality  Test  Directive  seeks  to  prevent 
unnecessarily restrictive regulation of professions from coming into effect by obliging Member States to 
assess thoroughly, before their adoption, the proportionality of any new or amended national regulations 

9 Commission Delegated Directive (EU) 2024/782 of 4 March 2024 amending Directive 2005/36/EC of the European Parliament 
and of the Council as regards the minimum training requirements for the professions of nurse responsible for general care, 
dental  practitioner  and  pharmacist;  Commission  Delegated  Directive  (EU)  2025/1223  of  10  April  2025  amending  Directive 
2005/36/EC of the European Parliament and of the Council as regards the minimum training requirements for the profession 
of veterinary surgeon. 
10 For example, Commission Delegated Decision (EU) 2021/2183 of 25 August 2021 amending Annex V to Directive 2005/36/EC 
of the European Parliament and of the Council as regards the evidence of formal qualifications and titles of training courses 
11 Directive (EU) 2018/958 of the European Parliament and of the Council of 28 June 2018 on a proportionality test before 
adoption of new regulation of professions (OJ L 173, 9.7.2018, pp. 25); 2022 Guidance on the assessment of proportionality 
pursuant to Directive 2018/958 on a proportionality test before adoption of new regulation of professions - Publications Office 
of the EU 

6 

 
 
 
of professions. Proportionate national regulatory requirements and effective recognition processes are key 
to ensuring the rights of EU citizens to access regulated professions across borders. 

Typically, the number of professions that are regulated is used as an indicator of the level of regulation 
of  professions.  However,  such  number  is  a  complex  and  multifaceted  indicator  that,  on  its  own,  is 
inadequate  for  assessing  the  regulatory  framework  concerning  regulated  professions.  Some  Member 
States may regulate a bundle of professional activities as one profession, while other may regulate each 
of these activities separately. Moreover, a Member State might regulate fewer professions but impose 
stringent requirements and detailed conditions on each, whereas another might regulate a larger number 
but with less stringent criteria. 

Therefore, while the count of regulated professions offers a starting point,12 a more nuanced analysis is 
essential for understanding each Member State's regulatory environment. This involves examining not only 
the number of professions regulated but also the  depth, restrictiveness, and underlying factors driving 
these regulations.  

1.4 Mobility of professionals 

As illustrated below, the top 20 most mobile professions identified for establishment between January 
2018 and December 2023 are mainly in the health, education, social, construction and business services 
sectors.   

Doctor of medicine
Nurse
Secondary school teacher
Physiotherapist
Dental practitioner
Child care worker
Primary school teacher
Nursing assistant / health care assistant
Veterinary surgeon
Lawyer / barrister / solicitor
Social worker
Pharmacist
Architect
Engineer
Psychologist

Kindergarten / nursery school / preparatory school…

Midwife
Fork list truck operator
Speech and language therapist
Radiographer / radiotherapist

45989

40772

34077

17675

15674

12786

9348
8954

7147
6280
5899

4620
4089
4011
3658
3108
2770
2698
1974
1905

12 According to the Regulated Professions Database, the number of regulated professions per Member State varies from around 
100 to 400. 

7 

 
 
 
 
 
Most mobile professions for establishment between 2018 and 2023 based on information in the Regulated Professions 
Database 

In terms of temporary service provision , the top 10 most mobile professions identified were mainly in the 
sport and leisure, transport, construction and commercial sectors between January 2018 and December 
2023 (chart below).  

Ski and/or mountain/canyon guide/mountain leader

4217

Ski instructor

12240

Tourist guide

Fork lift truck operator

Welder / steel worker

Joiner / Carpenter

3409

3044

1943

1852

Locksmith

1633

Sports instructor

Air conditioning/Heating/Central heating/ventilation
equipment technician/installer/repairer/maintenance

Veterinary surgeon

1394

1374

1342

Most mobile professions for temporary provision of services between 2018 and 2023  based on information in the 
Regulated Professions Database 

2. General system of recognition  
The general system under Directive 2005/36/EC applies to regulated professions that are not covered by 
automatic recognition based on minimum training requirements or on professional experience. Under the 
general  system,  the  host  authority  compares  the  applicant’s  training  and  qualifications  with  its  own 
national requirements. This system provides a structured, case-by-case mechanism to facilitate mobility 
while allowing Member States to maintain their own standards. 

Information on the procedure to apply for recognition under the general system has been collected from 
competent authorities for the following four professions: radiographers, secondary school teachers, health 
care  assistants  and  social  workers.  These  specific  professions  were  chosen  to  get  more  precise  and 
comparable input per Member State. The 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 .  

Fees 

Fees for the recognition of professional qualifications vary widely across Member States. The chart below 
summarises the fees as reported by competent authorities in Member States.  For the four professions 
analysed (radiographers, secondary school teachers, healthcare assistants, social workers), fees are low 
(no fee or below 100 EUR) in the majority of Member States. However, some Member States charge more 

8 

 
 
 
substantial fees, with Finland reporting fees ranging from 1.000 to 2.000 EUR for radiographers, healthcare 
assistants and social workers applying for recognition of their qualifications. 

9

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3

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9
9
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1

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4

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E
0
0
0
.
1

Radiographers (n=13)

Secondary school
teachers (n=14)

Healthcare assistants
(n=11)

Social workers (n=12)

Number of Member States applying ranges of fees for recognition procedures in four selected professions, 
based on replies received from competent authorities 

In most cases, a specific fee is charged to cover the administrative work necessary to assess qualifications 
from other Member States to ensure alignment with  national requirements. However,  from the above, 
three other types of fees also exist among Member States in relation to the recognition procedure under 
the  general  system:  expert  fees,  signifying  a  specialised  evaluation  of  qualifications  by  professional 
experts; a fee for lack of documentation, serving as an incentive for applicants to present comprehensive 
files and thereby streamlining the assessment process; or fees calculated as a percentage of the national 
minimum wage, linking the fee directly to economic conditions and reflecting a dynamic alignment with 
the domestic economic context. 

In many cases no fee is charged in relation to the recognition procedure under the general system. This 
approach aligns with efforts to minimise barriers to professional mobility to the benefit of applicants and 
might indicate a policy focus on removing financial barriers to professional mobility and facilitating easier 
access to the labour market for qualified individuals. 

Length of procedure 

Under Article 51(2) of the Directive, the procedure for examining an application for recognition must be 
examined  as  quickly  as  possible  and  as  a  maximum  within  four  months  after  the  date  on  which  the 
applicant’s  complete  file  was  submitted.  Member  States  generally  consider  it  realistic  to  examine  an 
application within the deadline of four months. All reporting competent authorities for the professions of 

9 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
radiographer and health care assistant, and almost all for the professions of secondary school teacher and 
social worker consider that the deadline is realistic. Almost all reporting Member States13 have a system 
in place which records when a recognition procedure of an applicant begins and when the recognition 
procedure ends.  In several Member States, the length of the recognition procedure for all four professions 
is generally shorter than the maximum four months required under the Directive.  

For radiographers, recognition procedures vary widely, ranging from around 20 days in the most efficient 
systems to up to four months in the slowest, with most applications processed within two to three months. 
For secondary school teachers, processing times range from as little as two weeks to about four months, 
though in certain cases—particularly where additional  documentation or staffing constraints arise—the 
process may extend up to eight months. For healthcare assistants, recognition procedures generally take 
between 20 days and seven months, with most completed within one to four months, reflecting differences 
in administrative capacity and the complexity of assessing qualifications. For social workers, recognition 
times are typically shorter, ranging from about one week to four months, with most applications finalised 
within one to three months. 

For  all  four  professions,  competent  authorities  report  several  aspects  that  can  cause  delays  to  the 
recognition procedure. The main issue reported concerns missing documentation or information. Several 
competent authorities also point to the fact that expert evaluations can further delay the process, or report 
delays in relation to responses via IMI when there is a need to verify documents with other Member States. 
Some Member States also mention difficulties in comparing foreign qualifications with national standards 
or in cases where compensation measures are being considered which necessitate further clarifications 
from applicants. A few competent authorities also raise issues in relation to staffing and high workload. 

Document requirements 

For the purpose of establishment, documents that may be required by competent  authorities are listed 
exhaustively in Annex VII of Directive 2005/36/EC. The chart below illustrates how many documents are 
typically  required  from  applicants  in  different  Member  States.  Data  is  based  on  replies  received  from 
responding competent authorities.  

13 Questions on length of the procedure were answered by 13 MS for radiographers, 16 MS for secondary school teachers, 12 
MS for healthcare assistants, and 12 MS for social workers.   

10 

 
 
 
10

8

7

8

2

1

2

1

1

6

4

2

up to 5 5-10 more
than 10

up to 5 5-10 more
than 10

up to 5 5-10 more
than 10

up to 5 5-10 more
than 10

Radiographers (n=13)

Secondary school
teachers (n=16)

Healthcare assistants
(n=11)

Social workers (n=12)

Number of Member States that indicate that they typically require “up to 5”, “5 to 10” or “more than 10” 
documents from applicants in the four selected professions 

Proof of nationality, proof of qualification and attestations of professional experience are the 
documents most frequently required for all four professions examined. 

For radiographers, the documents most commonly required by Member States include proof of nationality 
and proof of qualification. An attestation of professional experience is generally required, though only a 
few Member States request it systematically. Proof of good character or repute or that the person has not 
been  declared  bankrupt  or  suspended  or  prohibited  to  pursue  that  profession  in  the  event  of  serious 
professional misconduct or a criminal offence is required only by some Member States. A declaration under 
oath or documentation on physical or mental health is only systematically requested in one Member State. 
Proof of financial standing is generally not requested, while evidence of professional liability insurance is 
occasionally required.14  

For  secondary  school  teachers,  proof  of  professional  qualifications  is  consistently  required  across  all 
Member States. Proof of nationality is also widely requested, although not always on a systematic basis. 
Attestations of professional experience are generally required, but only a minority of Member States ask 
for them systematically. Proof of good character, professional repute, or confirmation that the applicant 
has not been subject to serious professional misconduct, prohibitions, suspensions or criminal convictions 
are applied only by a limited number of Member States. Documents concerning the applicant’s physical or 
mental health are rarely required. Declarations under oath or solemn declarations are also uncommon. 

14 The number of documents required is on average between 5 and 10 across Member States, and the number of pages is on 
average between 10 and 20. This is similar in the other three general system professions examined. 

11 

 
 
 
 
Finally, no reporting Member States require proof of financial standing or evidence of insurance against 
financial risks arising from professional liability. 

As regards healthcare assistants, proof of professional qualifications is systematically required. Proof of 
nationality  is  also  consistently  requested,  although  in rare  cases  it  may  be  required  only  occasionally. 
Attestations of professional experience are generally required, but only a limited number of Member States 
request them on a systematic basis. Proof of good character or repute or that the person has not been 
declared bankrupt or suspended or prohibited to pursue that profession in the event of serious professional 
misconduct  or  a  criminal  offence  are  only  required  by  few  Member  States.  Requirements  relating  to 
physical or mental health are limited to a few Member States. Proof of insurance against financial risks 
arising  from  professional  liability  is  also  rarely  required.  Finally,  no  reporting  Member  States  require 
declarations under oath, certifications of authenticity, or proof of financial standing. 

For social workers, the documents most frequently required by reporting Member States begin with proof 
of qualification, which is systematically requested across all of them. Proof of nationality is also generally 
required. Attestations of professional experience are widely required as well. Around half of the reporting 
Member  States  require  attestations  confirming  the  absence  of  professional  suspensions  or  criminal 
convictions. Proof of good character or repute or confirmation that the applicant has not been bankrupt, 
suspended, or prohibited from practising due to serious misconduct is required by some Member States 
systematically and by others only occasionally. Requirements relating to physical or mental health remain 
limited. Declarations under oath or solemn declarations are requested systematically by very few Member 
States. Proof of financial standing is not required by any reporting Member State, and only a small number 
occasionally request evidence of insurance against financial risks arising from professional liability. 

Electronic procedures 

While in some cases applicants can and choose to complete the full recognition procedure via electronic 
means, this possibility is not used on equal footing in all Member States. The chart below illustrates for 
each  of  the  four  professions  for  which  data has  been collected,  the number  of  Member  States  where 
applicants can complete the full recognition procedure via electronic means. 

12 

 
 
11

1

15

14

5

8

16

7

4

15

4

8

Radiographers

Secondary school
teachers

Healthcare
assistants

Social workers

Yes

No

N/A (no data or not regulated)

Number  of  Member  States  where  candidates  can  fully complete  the  recognition  procedure  via  electronic 
means (“yes”), in the four selected professions  

Although for the profession of radiographer, applicants can complete the full  recognition procedure via 
electronic means  in  several Member States, applicants opt for electronic procedure to varying degrees 
(ranging from 10% in Croatia to over 95% in Ireland, Portugal, Finland and Denmark). In Member States 
where it is not possible to complete the full recognition procedure via electronic means, documents such 
as certified copy and official translations of the diploma and curriculum are requested on paper.  

The situation is similar as regards the use of electronic procedures for the profession of secondary school 
teacher, which is available in almost all Member States. In the Member State where it is not possible to 
complete the full recognition procedure via electronic means, documents requested on paper are: official 
identity document indicating nationality; medical certificate or declaration by the applicant, criminal record, 
diplomas, certificates, description of studies, document issued by the competent authority of the country 
where the professional qualification for teaching was obtained, and certificate of language proficiency. 

Only  four  reporting  Member  States  (Denmark,  Italy,  Portugal  and  Romania)  offer  a  fully  electronic 
recognition  procedure  for  health  care  assistants  and  the  use  thereof  varies  considerably  (from  5%  in 
Romania to over 95% in Italy, Portugal and Denmark). In the other reporting Member States, documents 
requested on paper are: application, curriculum vitae, birth and/or marriage certificate, passport, evidence 
of formal qualifications (diploma, certificates, overview of subjects and hours, certified copy and official 
translations of the diploma and curriculum, proof about future employers, language certificate certificates 
of good conduct, medical certificate of health suitability for the practice of the profession. 

13 

 
 
  
As regards social workers, the full recognition procedure is available via electronic means in all but four 
Member States, and preference for it varies from less than 10% in Hungary and Lithuania to over 95% of 
applicants Ireland and Finland. In Member States where is not possible to complete the full recognition 
procedure via electronic means, documents requested on paper are those relating to the qualification and 
employment, criminal record and medical certificate. 

Administrative cooperation 

Efficient administrative cooperation among Member States across all professions is necessary to ensure 
that  recognition  decisions  are  issues  without  delay,  and  within  the  decision-making  deadlines.  The 
cooperation  (mutual  assistance)  is  based  on  Internal  Market  Information  (IMI)  system.  The  IMI  system 
provides a secure communication channel for competent authorities to exchange information and verify 
the authenticity and validity of a professional's qualifications, diplomas, and professional experience. The 
authorities may also seek more general information, e.g., concerning the professional regulation in a home 
Member State. It mitigates language barriers by enabling automatic translation, and it helps the competent 
authorities identify a correct counterpart in another Member State,  

The questions host Member States often ask home Member States while processing applications under the 
general system pertain to the following issues: 

• 

Information  on  egulation  of  the  profession  and  organisation  of  training:  The  foremost 
category of questions pertains to the profession and training provided in the home Member State. 
Host countries frequently inquire about the specific professional activities covered by the profession, 
the  level  of  qualification,  and  the  duration  of  the  training.  Furthermore,  they  request  detailed 
information on the content of the practitioner's training and whether the education and profession 
are regulated.  

•  Experience  and  right  to  practise:  Another  common  set  of  questions  concerns  the  applicant’s 
practical experience and entitlement to practise the profession. Host Member States seek to ascertain 
whether they are qualified to exercise the profession in their home country. Additionally, they want to 
determine which profession the practitioner has the right to practise and whether the diploma grants 
access to a regulated profession.  

•  Authenticity of documents: Questions about the authenticity of documents also rank highly among 
the inquiries. This includes verifying whether the professional in question is the rightful owner of the 
documents, if the diploma is genuine, and whether the certificate complies with Directive 2005/36/EC. 

•  Disciplinary and criminal records: Questions regarding the absence of disciplinary sanctions and 
criminal records are also among the most asked. Host Member States frequently request confirmation 
that  the  professional  is  not  subject  to  any  disciplinary  or  criminal  sanctions,  either  in  the  home 
Member State or elsewhere. They seek assurances that the professional has not been suspended or 
had their right to practise withdrawn due to gross negligence or violations of criminal law. 

Compensation measures 

14 

 
 
 
 
 
The  general  system  allows  for  the  recognition  of  professional  qualifications  across  Member  States, 
occasionally necessitating compensation measures to address differences in qualifications. Compensation 
measures  may  be  implemented  when  substantial  differences  are  identified  that  cannot  be  offset  by 
professional  experience  or lifelong learning.  To  determine  whether substantial  differences  exist  for  the 
profession in question, Member States carry out a comparison between the training which the applicant 
followed with the national training in place in the Member State. As a rule, when compensation measures 
are  imposed,  Member  States  must  leave  to  the  applicant  the  choice  between  an  aptitude  test  and 
adaptation period.15  

Professions 

Overall number of 
positive recognition 
decisions (2018-
2023) 

Overall number of 
positive recognition 
decisions with 
compensation 
measures (2018-
2023) 

Positive recognition 
decisions with 
compensation 
measures as % of 
all positive 
recognition 
decisions 

Overall number of 
negative 
recognition 
decisions (2018-
2023) 

Secondary school 
teacher 

Physiotherapist 

Childcare worker 

Nursing Assistants 
and Health Care 
Assistants 

Primary school 
teacher 

Lawyer/Barrister/So
licitor 

Engineer 

Psychologist 

Kindergarten 
teacher/ Nursery 
school 
teacher/Preparator
y school teacher 

Speech and 
language therapist 

13 312 

13 135 

9 002 

4 469 

4 012 

5 079 

3 141 

2 219 

1 885 

1 281 

4 135 

2 096 

2 692 

948 

1 150 

456 

19 

239 

271 

397 

31% 

15,9% 

32,9% 

21,2% 

28,7% 

8,9% 

0.6% 

10,7% 

14,4% 

30,9% 

7 559 

507 

2 254 

1 172 

899 

110 

39 

324 

414 

46 

Number  of  positive  decisions  taken  without  the  need  for  compensation  measures,  positive  decisions  following 
successful completion of compensation measures, and negative decisions after compensation measures for  the 10 
most mobile professions under the general system. 

15 Member States may derogate from the requirement to give the applicant a choice between adaptation period and aptitude 
test  for professions whose pursuit requires precise knowledge of national law and in respect of which the provision of advice 
and/or assistance concerning national law is an essential and constant aspect of the professional activity (Article 14(3) of the 
Directive).  

15 

 
 
 
 
 
For the 10 most mobile professions in the context of establishment, the table above gives an overview of 
the number of positive recognition decisions per profession, the number of positive recognition decisions 
with compensation measures per profession and the number of negative decisions per profession, based 
on data from the Regulated Professions Database for the period 2018 to 2023.  The numbers included in 
this table highlight varying reliance on compensation measures across different professions. The use of 
compensation  measures  for  the  professions  of  radiographer,  secondary  school  teacher,  healthcare 
assistant and social worker also varies.  

As regards radiographers, most reporting Member States appoint an expert to assist with the comparison 
of qualifications,  while only a few focus specifically on core subjects and the competencies needed to 
ensure safe radiography practice. All Member States consider whether knowledge, skills, and competences 
gained through professional experience or lifelong learning can compensate for substantial differences 
identified. Challenges arise in assessing these differences, including difficulties evaluating competencies 
and learning outcomes, uncertainties related to curricula, teaching methods, and assessment practices, as 
well as  significant variations  in professional profiles or education systems that may require additional 
training  rather  than  compensation  measures.  Differences  in  what  is  considered  crucial  depending  on 
practice settings may also require discussion to ensure safe practice. Where compensation measures are 
imposed,  applicants  generally  have  the  option  of  an  aptitude  test  or  an  adaptation  period,  although 
exceptions exist, and some Member States occasionally require additional training or testing. Adaptation 
periods range from 1–2 weeks to one year, averaging around six months, while aptitude tests typically 
take 1.5 months to one year, with an average of 3–6 months. These waiting periods are due to the need 
to coordinate schedules, arrange venues, and design tests tailored to the identified substantial differences. 

For  the  profession  of  secondary  school  teacher,  only  a  few  Member  States  focus  specifically  on  core 
subjects, and only some appoint experts to assist with the assessment. Criteria for identifying substantial 
differences vary, including deviations from training regulations, mandatory subject requirements, essential 
apprenticeships,  and  acquisition  of  pedagogical  knowledge  and  practice.  While  most  Member  States 
examine whether professional experience or lifelong learning can compensate for substantial differences, 
a  few  do  not.  Challenges  in  assessment  include  limited  information  on  training  content,  mismatches 
between  foreign  and  national  education,  and,  in  some  cases,  administrative  complexities  due  to  the 
decentralisation of education responsibilities. Where compensation measures are imposed, applicants are 
generally allowed to choose between an aptitude test and an adaptation period, although in certain cases 
this choice is limited due to the nature of the required experience or internships. Adaptation periods range 
from 6 months to 3 years, depending on the identified differences and the time needed to meet required 
standards,  while  aptitude  tests  typically  take  around  6  months  on  average,  with  timing  depending  on 
institutional arrangements and administrative procedures. These waiting periods are due to the need to 
ensure proper planning, coordination, and implementation of the measures. 

For healthcare assistants, only a few Member States focus on core subjects or appoint experts to support 
assessments. All  Member  States  examine  whether  knowledge,  skills,  and  competences  gained  through 
professional  experience  or  lifelong  learning  can  compensate  for  substantial  differences.  Challenges 
reported include the high diversity of training programs and professional profiles across Member States, 
which can make assessment difficult. Where compensation measures are required, applicants are generally 
offered  a  choice  between  an  aptitude  test  and  an  adaptation  period,  though  the  aptitude  test  is  not 
frequently selected. In cases where choice is limited, this is often due to practical constraints such as the 

16 

 
 
unavailability of suitable placements for adaptation periods. Adaptation periods typically range from 1 
month to 1 year, averaging around 6 months, while aptitude tests take between 1.5 months and 1 year, 
with an average of 3–6 months. These waiting periods are  due to the need to allow sufficient time to 
organise and implement the measures. 

For  social  workers,  all  reporting  Member  States  assess  whether  knowledge,  skills,  and  competences 
acquired through professional experience or lifelong learning can compensate for substantial differences 
in training. Challenges in this assessment arise due to variations in national training requirements. Where 
compensation measures are imposed, applicants are generally allowed to choose between an aptitude test 
and  an  adaptation  period,  although  guidance  may  be  given  to  direct  applicants  toward  the  most 
appropriate measure based on the differences identified. Adaptation periods range from 2 months to 3 
years, depending on the nature of the differences and the time needed to meet required standards. Aptitude 
tests are less commonly chosen, and the time needed to organise them is usually 2 to 3 months. Waiting 
periods are due to a need to allow adequate time for test preparation and organisation. 

Partial access 

In the context of Directive 2005/36/EC, partial access means that a professional who is fully qualified in 
their  home  Member  State  may  be  authorised  to  carry  out  only  part  of  the  activities  of  a  regulated 
profession in the host Member State, rather than the full scope of that profession. This applies when the 
applicant’s training covers a clearly separable subset of the host profession’s activities and when requiring 
them  to  complete  full  additional  training  would  be  disproportionate.  Partial  access  can  be  useful  for 
professionals exercising a professional activity that does not exist as a profession in its own right in the 
Member State to which they wish to move but instead is included as part of activities of another regulated 
profession. The concept of partial access was developed by the Court of Justice of the European Union and 
integrated into Directive 2005/36/EC by the amending Directive 2013/55/EU in Article 4f.  

Among national competent authorities responsible for recognition of professional qualifications for the 
profession of radiographer, teacher, social worker and healthcare assistant, 20 Member States responded 
to the question on the application of partial access in the past 5 years. Some Member States mentioned 
challenges in the application of the system. First, some referred to the fact that the conditions under the 
Directive are so difficult to be met that the application of partial access is difficult in practice. They indicate 
for  instance  that  it  is  very  difficult  to  delimit  the  tasks  and  sub-areas  that  a  professional  can  do,  as 
activities are often interrelated. Specifically, regarding the profession of social workers several Member 
States  noted  that  it  is  not  possible  to  objectively  separate  the  activities  attributed  to  the  profession. 
Second, some Members States raised difficulties in categorizing and integrating in the professional practice 
persons with partial access to one of the regulated health professions since the regulated health care 
professions  with  their  scope  of  activities  are  strongly  embedded  in  the  national  health  care  systems. 
Another challenge raised was the difficulty for national authorities to supervise the persons with partial 
access  in  professional  practice.  Furthermore,  one  Member  State  noted  that  partial  access  creates 
challenges regarding the reimbursement through the mandatory health insurance. 

Measures to improve the application of partial access suggested by Member States included suggestions 
for  exchange  of  experience  and  good  practices  between  the  Member  States  in  this  area  and  more 
transparency between Member states to better understand different professional roles and professional 
autonomy  of  similar  professions  in  different  Member  States.  In  general,  application  of  partial  access 

17 

 
 
assumes that the recognition authorities and the applicants would  communicate during the recognition 
process to establish whether partial access could be a viable solution for an applicant. Most individuals 
are unlikely to be fully aware of the possibility to obtain partial access to a profession and will therefore 
often  not  be  in  a  position  to  expressly  request  it  after  having  their  request  for  recognition  rejected 
concerning full access to the profession. 

3. Automatic recognition based on professional 

experience  
According to the stakeholders consulted16, many of the professions for which the Directive envisages the 
possibility  of  automatic  recognition  based  on  professional  experience17,  suffer  from  shortages.  While 
shortages  vary  significantly  between  Member  States  and  regions,  they  are  prevalent  in  particular  in 
construction,  manufacturing  and  services.18  Despite  high  demand  for  the  professions  concerned,  from 
2018 to 2023, the automatic recognition regime based on professional experience has  seen generally 
limited usage across the EU.19  

Among the professions benefiting regularly from automatic recognition based on professional experience 
in the period 2018 to 2023 have been professions in construction/crafts and the hospitality sector: Painter-
decorator, Mason/Bricklayer, Electrical equipment/appliances contractor/repairer/installer, Joiner/Carpenter 
and  Restaurant  owner/manager/Caterer/Catering  manager/Banquet  organiser.  Positive  recognition 
decisions for these professions ranged around a few hundred per year.20 In comparison to the thousands 
of positive decisions reported for sectoral professions or for professions under the general system, the 
numbers for the recognition regime based on professional experience appear relatively modest.Personal 
services,  such  as  hairdressers  and  aestheticians,  also  benefitted  from  the  recognition  based  on 
professional experience.21  

16 SME United and Business Europe 
17 It is estimated that there are around 570 regulated professions falling under Annex IV across the EU. This number is based 
on the professions notified by Member States in the database of regulated professions as benefiting from automatic recognition 
of professional experience under Annex IV. It does not include craft professions that might have been incorrectly reported in the 
database as falling under the general recognition system. 
18 On construction and manufacturing professions among shortage occupations see 2024 EURES “Report on labour shortages 
and surpluses”.  
19 The reporting shows varied usage across Member States: nearly half use it from minimally to regularly, and nearly half do 
not report any decisions.  
20 This dominance of construction and crafts’ professions in the automatic recognition regime under Annex IV is also confirmed 
by the replies to the surveys by the group of coordinators and competent authorities. Competent authorities referred specifically 
to the professions of electrical installer/repairer/ equipment/engineering, crane operators, plumber, carpenter, tiler, masonry, 
decoration and finishing, steel and metal workers and repair of motor vehicles, as the professions  for which  the automatic 
recognition regime under Annex IV is used the most. 
21 This finding is based on the replies by competent authorities. Additionally, individual Member States and competent authorities 
have  highlighted  professions  like  freight  forwarder,  wholesale  intermediary,  retail  trade,  health  and  safety  at  work,  tour 
managers, and travel agency managers as being involved in procedures for recognition of professional qualifications based on 
professional experience. 

18 

 
 
 
3.1 Annex IV professions22 

The primary advantage of the Annex IV system according to competent authorities is its speed and reliance 
on professional experience rather than formal training. Competent authorities generally find the criteria for 
assessing professional experience easy to verify, especially with certificates from the home Member State 
stating the nature and duration of the activity. However, the views as regards the user-friendliness of the 
lists of activities included in Annex IV seem rather mixed (see below).  

The limited application of this regime could have several causes including the lack of user-friendliness or 
suitability of the lists of activities laid down in Annex IV23 to which the regime of automatic recognition on 
the basis of professional experience applies; the fact that many of these professions are not regulated in 
several Member States; the incorrect application of the general system to Annex IV professions when the 
system of automatic recognition should be applied and incomplete or incorrect reporting of recognition 
decisions in the Regulated Professions Database.24 

Survey  responses  from  stakeholders  on  the  user-friendliness  of  the  lists  in  Annex  IV  present  a  mixed 
picture particularly regarding their accuracy, clarity, specificity, and relevance to current needs.25 70% of 
the responding competent authorities consider the current nomenclature still sufficiently accurate to cover 
the economic activities in the crafts, commerce and industry professions in their Member States. When 
asked whether the scope of the activities that fall under Annex IV is sufficiently clear, 60% of the competent 
authorities replied affirmatively. 55% of competent authorities did not consider necessary to further specify 
the scope of certain activities. As regards whether the list of activities under Annex IV can be considered 
adapted to the current needs of professionals, 55% of competent authorities and 50% of Member States’ 
experts  replied  in  the  affirmative.  When  interpreting  this  data,  it  is  important  to  note  that  competent 
authorities satisfied with the current Annex IV lists account for 95% of reported recognition decisions over 
the past five years, but at the same time Member States’ experts advocating for clarification and updates 
also represent countries in which positive recognition decisions under Annex IV are issued the most.26 This 
divergence  in  opinions  makes  it  challenging  to  draw  definitive  conclusions  about  satisfaction  with  the 
current lists.  

Stakeholders  who  find  the  Annex  IV  lists  insufficiently  precise  or  up-to-date  highlight  that  the  lists' 
extensive nature and broad definitions make it difficult to determine which activities are covered.  They 
highlight that the lists are considered outdated, as they include many currently unregulated activities while 
excluding  emerging  sectors  with  regulated  professions.  Thus,  modernisation  of  these  lists  is  deemed 

22 It is important to note that there was a limited response rate for many questions regarding the functioning and effectiveness 
of  the  Annex  IV  recognition  regime.  This  was  true  for  both  the  survey  conducted  with  national  experts  from  the  group  of 
coordinators and the survey directed at competent authorities. Additionally, participation in the competent authorities’ survey 
was restricted to two authorities per Member State. 
23 This list is a consolidation of the lists in 13 directives that were adopted from the 60’s to the 80’s and uses a nomenclature 
that dates back as far as 1958.  
24 In this regard it should be noted that some reporting competent authorities indicated to have taken recognition decisions 
based on Annex IV even though their Member State did not report any such decisions in the database. 
25  These  lists  were  originally  created  from  a  combination  of  13  different  older  directives,  with  the  professional  activity 
nomenclature dating back to 1958 without having been updated since. 
26 Such as Belgium. 

19 

 
 
 
desirable. In addition, it is suggested by some stakeholders that more details and guidelines about the 
functioning and applications of Annex IV could be provided.   

3.2 Application procedure  

The  large  majority  of  responding  competent  authorities  do  not  experience  specific  problems  when 
assessing the level of professional experience in terms of years of experience, level of responsibility or 
scope of activities in the context of an Annex IV recognition procedure. Those competent authorities that 
do report challenges state that it is difficult to assess the applicants’ qualifications if there is no certificate 
regarding the nature and duration of the activity, including any training. Furthermore, applicants sometimes 
provide too little detail regarding the work experience, even though it is essential to have an accurate 
description of the scope of activity to allow a determination of whether it is the same profession as the 
one regulated in the host Member State, which is a precondition to benefit from the recognition system 
under the Directive.  

Social  partners27  have  identified  several  challenges  impacting  the  recognition  process  for  Annex  IV 
professions. Key difficulties include regulatory differences across Member States, bureaucratic processes, 
and the administrative costs involved, such as translation fees and document authentication. Additionally, 
the  absence  of  digital  processes  and  the  complexity  of  interpreting  foreign  curricula  pose  significant 
barriers.  A challenge particularly relevant to professions in crafts, commerce, and industry sectors is the 
variation in health and safety requirements across Member States, which leads to diverse certification 
demands, which can in turn lead to barriers to access professions in these sectors.28 

Stakeholders  suggest  several  actions  at  national  level  to  address  these  challenges  in  professional 
recognition.  These  include  enhancing  the  transparency  of  the  qualifications  system,  streamlining  and 
simplifying  recognition  procedures  by  digitising  applications  and  processes  end-to-end,  and  reducing 
administrative hurdles such as document requirements. Some stakeholders also advocate for centralising 
the responsible authorities and clarifying their respective roles. 

Professional  associations  expect  clear,  transparent  information  about  the  recognition  process  and  its 
requirements. Additionally, stakeholders propose streamlining the recognition process through a unified, 
digitalised EU system for recognising qualifications, accessible via an online portal. Moreover, stakeholders 
urge the EU to promote talent attraction mechanisms and to make the hiring of third-country nationals 
more flexible. 

Competent authorities report that the recognition procedure under Annex IV typically takes around one 
month across Member States.29 Delays beyond this average timeframe are often due to factors such as 
missing documents, translation requirements, the necessity to request information via the Internal Market 
Information System (IMI), and the absence of certificates regarding the nature and duration of the activity 
from some home Member States. 

27 Business Europe and UEAPME 
28  Professions  where  these  challenges  are  said  to  be  the  most  significant  are  electricians  (high  complexity  of  recognition 
procedures, safety compliance requirements), plumbers (variability in national certification standards for plumbing, especially 
in water quality and hygiene rules), construction workers (specific national construction safety laws and diverging qualifications), 
carpenters and roofers (regional weather and climate conditions affect the techniques). 
29 This processing time refers to applications that are already complete, as inferred from the responses.  

20 

 
 
 
Regarding  the  costs  associated  with  recognition  procedures,  slightly  less  than  half  of  the  responding 
competent authorities do not charge an application fee. However, applicants may still incur costs related 
to translations and document authentication. The remaining authorities report average costs ranging from 
16 to 660 EUR. 30  

To complete an application file, competent authorities generally require 3 to 4 documents on average. The 
table  below  provides  an  overview  of  the  types  of  documents  and  the  frequency  with  which  they  are 
required by competent authorities: 

Always 
Required 

Sometimes 
Required 

Never 
Required 

Document Type 

Proof of nationality 

Attestations of competence/qualification 

Attestation of professional experience 

70% 

46%31 

54% 

Certificate  of  nature  and  duration  of  the  previous 
activity32 

38% 

Proof of good character 

Declaration on oath 

8% 

8% 

Documentation  of  physical  or  mental  health  of  the 
applicant 

0% 

Proof of financial standing 

0% 

Proof of insurance against financial risks arising from 
professional liability 

0% 

15% 

46% 

23% 

31% 

8% 

38% 

8% 

8% 

15% 

Attestation  of  absence  of 
suspensions or criminal convictions 

temporary  or  final 

0% 

7% 

15% 

8% 

23% 

31% 

84% 

54% 

92% 

92% 

85% 

93% 

Types of documents and frequency with which they are required by competent authorities 

Several respondents highlight that not all Member States issue the certificates listed above, necessitating 
alternative  forms  of  evidence  that  are  less  straightforward  to  verify,  and/or  requiring  the  recognition 

30 It is however not fully clear from the replies if the reported cost includes estimates of translation and authentication costs 
to be borne by the applicant. 
31 However, it should be noted that such attestations cannot be demanded by the host Member State if an applicant meets the 
conditions for recognition on the basis of professional experience alone. 
32 Issued by the competent authority of the home Member State or the Member State from which the professional comes. Some 
authorities think that an applicant’s professional experience can only be reliably demonstrated through such a certificate, or 
that such a document can provide information that is not available via IMI. However, in reality, the information available in IMI 
is what the respondent provides, and the list of predefined questions can be complemented according to identified needs. 

21 

 
 
 
 
authorities to make inquiries via IMI. This is said to prolong the application process. It is therefore suggested 
to introduce a mandatory common EU-wide document to serve as proof of professional experience.33 This 
structured template, uniformly used by all Member States, could minimize unclarities regarding the nature 
and  duration  of  an  applicant's  professional  experience.  Additionally,  competent  authorities  and 
stakeholders suggest that, as was done under the previous Directive 64/427/EEC, the Commission should 
publish lists of the relevant competent authorities. This would facilitate addressing the correct authority 
and speeding up the process of obtaining necessary information via IMI. 

Finally, the vast majority of respondents report having an authority that assists professionals with the 
necessary documentation under Annex IV, whether through assistance centres or professional associations 
and competent authorities. 

4. Automatic recognition based on minimum training 

requirements  

The primary objective of Directive 2005/36/EC is to remove barriers to professional mobility and provide 
professionals with the opportunity to practice their profession across the EU. The automatic recognition 
system based on minimum training requirements is a key component of achieving this goal. This system 
applies  to  professions  where  there  are  harmonised  minimum  training  requirements,  i.e.,  doctors  of 
medicine,  nurses  responsible  for  general  care,  dental  practitioners,  veterinary  surgeons,  midwives, 
pharmacists, and architects. 

4.1 Mobility in professions with harmonised minimum training requirements 

Mobility in these professions is crucial to respond to the shortages of professionals caused by an ageing 
population  and  healthcare  workforce,  skills  shortages  and  changing  demands.34  The  Directive  has 
facilitated such mobility: from 2020-2024 almost 78.000 recognition decisions were issued under this 
system. It applies to some of the most mobile professions including the two professions with the highest 
number of recognition cases for establishment (medical doctors and general care nurses). The system also 
demonstrates is high level of predictability for applicants, leading to a high share of positive recognition 
decisions between 96.8% and 99.5%. 

Recognition decisions taken under the system of automatic recognition based on harmonised 
minimum 
2020-2024  
training 
(source: Regulated Professions Database) 

requirements 

the 

EU, 

in 

Final decisions taken35 

% positive decisions 

33 Some respondents observed that under the original Directive 64/427/EEC, competent authorities in the countries of origin 
were required to issue certificates detailing the periods of practical professional experience. Additionally, a standard form for 
these certificates was published in the Official Journal of the EEC. The competent authorities in the Member States were also 
notified to the Commission, which regularly published updated lists. 
34 Enrico Letta - Much more than a market (April 2024).  
35 Final positive and negative decisions. Excludes on-going procedures, e.g. those that are still being examined or in an appeal 
procedure. 

22 

 
 
 
 
 
 
Medical 
doctors 
Nurses 
(general 
care) 
Dental 
practitioners 
Veterinary 
surgeons 
Pharmacists 
Midwives 
Architects 

30.536 

24.511 

11.042 

5.459 

2.803 
1.853 
1.788 

98.3 % 

96.8 % 

97.4 % 

99.5 % 

98.9 % 
98.3 % 
99.5 % 

4.2 Application procedure 

Overall, the application process for professions under the automatic recognition system of the Directive 
generally operates efficiently and effectively. With generally low application fees, adherence to procedural 
deadlines,  and  manageable  documentation  requirements,  the  system  supports  seamless  professional 
mobility. However, any move towards reducing application processing times below the maximum of three 
months as stipulated by the Directive (e.g. to one month) would require addressing existing bureaucratic 
and resource-related constraints to maintain the robustness of the process. 

Concerning application fees, stakeholder consultations indicate that fees for recognition applications for 
professions with automatic recognition based on harmonised minimum training requirements, range from 
€ 0 to € 700. 36 In ten Member States, no fees are applied for the recognition of medical doctors under 
the automatic recognition procedure. Similarly, several Member States charge no fees for nurses, while in 
many others  the fee remains below €100. Overall, this relatively modest fee structure supports broad 
participation and does not constitute a significant barrier to professional mobility. Only a small number of 
Member States apply higher charges—for example, one charges € 350 and another € 700.  

A key aspect of the automatic recognition process is its timeliness. The Directive requires the competent 
authorities to complete the recognition procedure as quickly as possible and within a maximum of three 
months after the date on which the applicant’s complete file is submitted (Article 51(2)).  

36 Access to practice requires an additional registration procedure in most Member States for some professions, e.g. doctors, 
which  might  be  separately  charged  and  might  require  provision  of  additional  documents,  e.g.  proof  of  language.  From  the 
stakeholder responses, it is not always clear whether the fee indicated covers both the application fee and the registration fee, 
and thus the fee required for the application itself might be lower than the numbers indicated here. In cases where Member 
States have indicated a specific registration fee, e.g. with a chamber, in their responses these fees do not seem excessive.  

23 

 
 
 
 
  
 
 
Figures on establishment in professions, 
based on data from the Regulated Professions Database (2018-2023)

Veterinary Surgeon

6927

Pharmacist

3883

Nurse

Midwife

2462

30463

Doctor of Medicine

39326

Dental Practitioner

12264

Architect

2492

0

5000

10000

15000

20000

25000

30000

35000

40000

45000

Figures on establishment 
based on data from the Regulated Professions Database (2018-2023) 
for the professions of veterinary surgeon, pharmacist, nurse, midwife, 
doctor of medicine, dental practitioner and architect

14838

15901

18553

16910

17806

13809

2018

2019

2020

2021

2022

2023

20000

18000

16000

14000

12000

10000

8000

6000

4000

2000

0

24 

 
 
 
 
 
 
 
 
 
 
Based on the stakeholder consultation, most competent authorities seem to adhere to the deadlines set 
out in the Directive. For instance, for doctors of medicine, only one competent authority has indicated that 
the procedure takes more than three months, while several Member States have procedures that are under 
a month. For the profession of general care nurse, only one Member State indicates that the procedure 
takes longer than the three-month deadline, while, again, several Member States have procedures that are 
under a month.  

The European Court of Auditors, in its 2024 special report37, recommended that the Commission, when 
proposing legislative changes, should consider reducing the timeline for processing recognition applications 
to one month. However, competent authorities indicate a divided stance on this feasibility. Some Member 
States indicate that it would be feasible to implement a reduced timeline of one month for the profession 
of doctors of medicine or general care nurses. However, many are not in favour of reducing the recognition 
procedure deadline to one month for either profession.  

Competent  authorities  cite  several  reasons  for  delays,  including  the  high  volume  of  requests,  staff 
shortages,  and  the  time  required  to  verify  the  validity  and  authenticity  of  documents,  which  is  often 
prolonged by late responses from the Member State of origin. Member States also note the need to move 
toward digital solutions to meet shorter deadlines. Some Member States further report that applicants’ 
failure to submit complete documentation contributes to longer procedures. However, since the procedural 
deadline begins only once a complete file has been submitted, such factors should not, in principle, affect 
compliance with the deadlines. Nevertheless,  this issue still reveals a broader challenge that can slow 
down the overall process. 

The application process for automatic recognition is also characterised by its specific requirements as to 
which  documents  a  host  Member  State  can  request  during  the  recognition  procedure.  By  eliminating 
unnecessary  complexity,  the  Directive  ensures  greater  efficiency  and  accessibility,  benefiting  both 
professionals  seeking  recognition  and  the  authorities  responsible  for  managing  the  procedures.  Data 
collection shows that Member States require submission of fewer documents compared to the general 
system. The chart below indicates the number of Member States typically requesting “up to 5” or “5-10” 
documents for the professions of doctors of medicine and nurses responsible for general care. No Member 
State indicated that more than 10 documents would be needed. 

37 https://www.eca.europa.eu/ECAPublications/SR-2024-10/SR-2024-10_EN.pdf  

25 

 
 
 
12

11

6

3

0

0

up to 5

5-10 more than

up to 5

5-10 more than

10

10

Doctors of medicine (n=15)

Nurses, general care (n=17)

As to the number of pages that applicants need to submit, close to 60% of Member States require 0-10 
pages of documents, nearly 40% require submission of 10-20 pages, and very few indicate submission of 
up to 20 pages.  

Delayed responses from the Member State of origin seems to be one of the main reasons for delays in 
the recognition procedure in the host Member States: 45% of competent authorities indicate that delays 
in the administrative cooperation with other Member States has impacted the ability to issue recognition 
decisions within the required deadline.  Member States indicate that the most frequently asked questions 
from the IMI list of predefined questions for the recognition process relate to holding a diploma listed in 
Annex V or good standing of the professional, or questions related to professional practice and activities 
covered  by  the  profession.  While  these  questions  can  be  legitimate,  they  may  lead  to  a  delay  in  the 
application process. Systematic submission of multiple questions  to other Member States  that are not 
really necessary for the purpose of the specific recognition process must be avoided.  

4.3 Minimum training requirements  

The  Directive  sets  out minimum  training requirements  separately  for  each  profession  concerned.  They 
differ in substance, length of training and other key elements. However, the common approach is that the 
Directive allows for the updating of minimum training requirements to account for scientific and technical 
advancements.  This  dynamic  adaptability  is  achieved  through  delegated  acts,  which  enable  periodic 
amendments  to  the  training  requirements  without  requiring  the  ordinary  legislative  procedure.  The 
objective of the delegated acts is to ensure that recognition of professional qualifications remains relevant 
and up to date with the latest knowledge and practices in each profession.38 

38 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  surgeon,  cf.  Commission 
Delegated Directive (EU) 2024/782 of 4 March 2024 and Commission Delegated Directive (EU) 2025/1223 of 10 April 2025. 
The Commission has also conducted a study concerning the profession of midwives and based on the Commission’s assessment 
of  the  study  conclusions,  the  minimum  training  requirements  for  midwives  might  also  be  updated  based  on  scientific  and 
technical advancements.  

26 

 
 
 
 
In the preparation of this Report, the Commission has conducted a comprehensive survey exercise to gather 
feedback on the functioning of the Directive in the context of minimum training requirements.  

The  information  gathered  from  competent  authorities,  coordinators  for  recognition  of  professional 
qualifications, professional organisations and other stakeholders has enabled the Commission to make 
some general observations. The document presents them separately for each profession, covering three 
main topics: 

•  Amendments and regular updates of training requirements: Stakeholders were asked about 
the  feasibility  and  benefits  of  allowing  all  minimum  training  requirements  for  professions  to  be 
updated regularly through delegated acts, rather than limiting this to specific elements currently listed 
in Directive 2005/36/EC. 

•  Appropriateness of current training durations: Feedback was requested on whether the existing 
minimum  lengths  of  training  (expressed  in  years  and/or  in  study  hours)  remain  appropriate  and 
whether  these  durations  should  be  altered.  Additionally,  the  surveys  addressed  the  sufficiency  of 
current minimum hours required for theoretical and practical training in medicine and dentistry.  

•  Enhancement  of  the  quality  requirements:  Concerning  the  medical  professions,  stakeholders 
provided input on whether the current emphasis on clinical training is adequate, and what changes 
might be necessary to enhance the practical experience of professionals in training. The necessity of 
updating the lists of minimum knowledge and skills requirements in light of ongoing scientific and 
technical developments was also discussed. This includes potential adjustments to better align with 
contemporary standards and practices, including transition from subject-based to competence-based 
training. 

Doctors of medicine  

Concerning  doctors  of  medicine,  the  Commission’s  delegated  powers  are  regulated  by  the  second 
subparagraph of Article 21(6), Article 21a(4), Article 25(5), and the second paragraph of Article 26 of 
Directive 2005/36/EC. These provisions allow the Commission to use its delegated powers to update a) the 
knowledge and skills concerning basic medical training; b) the titles adopted by the Member States for 
evidence of formal qualifications and, where appropriate, the body which issues the evidence of formal 
qualifications,  c)  the  certificate  which  accompanies  it  and  the  corresponding  professional  title;  d)  the 
minimum periods of training referred to in point 5.1.3 of Annex V; e) including in point 5.1.3 of Annex V 
new medical specialties common to at least two-fifths of the Member States. 

However, certain elements of the Directive can only be changed through ordinary legislative procedure. For 
example, the Directive does not give the Commission delegated powers to update the provisions of the 
Directive concerning minimum duration of basic medical training and the specialist medical training. The 
Commission  is  not  given  delegated  powers  to  amend  the  minimum  training  requirements  for  specific 
training in general medical practice, either. Even if scientific and technical progress or changes in national 
regulations result in changes of names of the medical specialties listed in Annex V, 5.1.3 of the Directive, 
the Commission can only amend the elements specific for the Member States and not the generic names 
of the profession included in the headers of the respective tables in Annex V, 5.1.3. 

27 

 
 
 
 
Nonetheless, the Commission is frequently contacted by stakeholders (for example national authorities or 
professional organisations) with specific requests for minor changes to the nomenclature (i.e. the generic 
names included in the tables in point 5.1.3 of Annex V), usually with a view to adjust it to the national or 
European standards. There are also calls for more substantial changes to the Directive. Only some of them 
could  be  addressed  within  the  delegated  powers  of  the  Commission.  For  this  reason,  the  Commission 
inquired whether, in the opinion of the stakeholders, the scope of the delegated powers and the execution 
of the delegated powers by the Commission is sufficient and whether amendments to those powers would 
be necessary in this respect. 

Stakeholders  generally  welcome  the  possibility  of  regularly  updating  minimum  training  requirements 
through  delegated  acts,  valuing  the  flexibility  and  timeliness  this  offers.  Some,  however,  stress  that 
delegated  acts  should  be  limited  to  technical  updates,  while  core  elements—such  as  the  duration  or 
location of basic medical training—should only be amended by legislation. They underline the need to align 
training with evolving needs and technologies without compromising educational stability or patient safety, 
while cautioning that overly frequent updates could disrupt training institutions. In this regard, stakeholders 
emphasise the importance of stable minimum standards complemented by clearer core competences and 
training pathways to support automatic recognition. A recurring concern relates to the role of Member 
States in defining minimum training requirements. Stakeholders warn that expanding the Commission’s 
delegated powers could affect the recognition system without sufficient Member State scrutiny, and they 
call for stronger information exchange among national authorities to safeguard national competences. 

Based  on  the  survey,  several  key  issues  have  emerged  concerning  the  appropriateness  of  the  current 
training durations for doctors of medicine outlined in the Directive. Concerning basic medical training, there 
is a consensus that the current minimum length of training, which is five years, accompanied by 5 500 
hours of theoretical and practical training, is generally appropriate. Reducing this time could adversely 
affect patient safety and the quality of medical education. On the other hand, few respondents advocate 
for extending this to six years to better align with the complexity and advancements in medical knowledge. 
However, there were no specific calls to extend the minimum requirement of the total number of 5 500 
hours of training.  

With respect to general practitioners, there is a significant push to extend the minimum training duration 
for general practitioners from three to at least four years, reflecting the complexity of the role in primary 
care and the need for general practitioners to manage a broad spectrum of health conditions. However, 
unlike in the case of medical specialties, there appears to be more variation as concerns the minimum 
training duration for general practitioners (family doctors).  

Concerning specialist doctors, there is a strong view that the minimum training duration should align with 
the  European  average  rather  than  the  lowest  common  denominator.  This  reflects  a  need  for  certain 
specialties to have longer training periods to ensure comprehensive skill acquisition.  

It appears that there is a  common accord that three years’ duration (which is a minimum for several 
medical specialties in the Directive) is no longer adequate and does not represent the current state of 
medical  knowledge  and  practice.  For  the  majority  of  specialties,  there  is  indeed  no  evidence  that  any 
Member State applies a three years’ training to the specialties in question and thus the minimum training 
requirement in the Directive seems to have become somewhat obsolete. 

28 

 
 
Member State 

AT 

BE 

BG 

HR 

CZ 

CY 

DK 

EE 

FI 

FR 

DE 

EL 

HU 

IE 

Minimum duration of 
training (general 
medical practice / 
family medicine) 

3.5 years 

3 years 

3 years 

4 years 

3 years 

5 years 

5 years 

4 years 

6 years 

4 years 

5 years 

5 years 

3 years 

4 years 

Member State 

Minimum duration of 
training (general medical 
practice / family 
medicine)   

IT 

LV 

LT 

LU 

MT 

NL 

PL 

PT 

RO 

SL 

SI 

ES 

SE 

3 years 

3 years 

4 years 

3 or 4 years 

3 years 

3 years 

4 years 

4 years 

4 years 

3 years 

4 years 

4 years 

5 years 

Training duration – family doctors / general practitioners. Source: EC survey and WONCA Europe / UEMO 

Medical Specialty 

Number of Member States 

Minimum duration 

where the duration 

(Annex V) 

corresponds to the 

minimum duration 

Anaesthetic 

Ophthalmology 

Otorhinolaryngology 

General Haematology 

Endocrinology 

3 years 

3 years 

3 years 

3 years 

3 years 

29 

0 

0 

0 

0 

0 

 
 
 
 
 
Physiotherapy 

Dermato-venereology 

Allergology 

Stomatology 

3 years 

3 years 

3 years 

3 years 

0 

1 39  

0 

0 

Medical specialties with minimum 3 years duration according to Directive 2005/36/EC. Source: EC survey and ENMCA 
survey 

Concerning  doctors  (basic  medical  training)  and  specialist  doctors  several  comments  were  raised 
concerning  content  and quality  of  training.  Concerns  were  raised  regarding  the  consistency  of  training 
quality across different training facilities, with a call for robust quality assurance frameworks to monitor 
and maintain minimum training standards. A transparent accreditation procedure for medical schools is 
advocated  to  enhance  trust  between  Member  States  and  facilitate  automatic  recognition.  This  is 
particularly relevant in the context of increasing privatisation in medical education. There is a significant 
emphasis on ensuring that training programmes adequately cover both theoretical and practical aspects 
of  medicine.  Stakeholders  suggest  the  inclusion  of  competency-based  frameworks,  to  provide  a 
comprehensive scope of abilities necessary for medical practice across various domains. 

Several stakeholders mentioned that the training curriculum should integrate modern technologies, such 
as telemedicine and digital tools, to prepare future doctors for contemporary healthcare settings while 
ensuring patient safety. It was also recommended that training curricula place more emphasis on social 
determinants of health and preventive medicine, moving beyond solely clinical training to address broader 
public  health  challenges  effectively.  Stakeholders  also  welcome  incorporating  competencies  such  as 
diagnostics,  treatment  planning,  and  understanding  the  implications  of  genetic,  digital,  and  artificial 
intelligence  advancements  in  medicine.  In  their  view,  the  training  environment  should  extend  beyond 
hospitals to include primary healthcare centres and diverse clinical settings to prepare doctors for a wide 
range of medical activities. They would also like to see a certain level of integration with specialist training, 
and mention that general medical practice today is seen as one more medical specialty with the critical 
role of primary care and adequate preparation for the challenges of modern healthcare systems.  

General care nurses 

Concerning  nurses,  Art.  31(2)  gives  the  Commission  delegated  powers  concerning  amendments  to  the 
training programme for nurses responsible for general care set out in point 5.2.1 of Annex V with a view 
to adapting it to scientific  and technical progress.  There is no clear preference across  stakeholders on 
whether all minimum training requirements should be subject to a regular updates via delegated acts. 
Most National Coordinators see this possibility positively, while professional associations and competent 
authorities have diverging views.  

Almost all consulted stakeholders consider that the current minimum length of training in years and the 
minimum hours of theoretical and clinical training are still appropriate and  that lowering the minimum 
length of training could have an adverse effect on patient safety. 14 competent authorities were in favour 
of including practice in simulated situations as a part of the minimum clinical training hours, two Member 

39 Under analysis by the national authorities. 

30 

 
 
 
States were against such inclusion while others did not provide any response40. Only 3 national professional 
associations were in favour, 5 were against and others did not respond. professional associations were in 
favour, 5 were against and other Professional associations 

In general, stakeholders consider the current list of competences in Article 31(7) of the Directive adeqate.   
A majority of competent authorities and professional associations supports the combination of training 
subjects and minimum competences in the training programme for nurses responsible for general care 
(Annex V, point 5.2.1).  

In  addition  to  matters  related  to  minimum  training  requirements  for general  care nurses,  professional 
associations also raised points related to tendencies in the organisation of healthcare systems by some 
Member States: general care nurses being replaced by healthcare assistants or confusion in some countries 
caused  by  the  creation  of  “parallel”  professions  performing  very  similar  tasks.  The  professional 
organisations stressed the need to reserving the title of nurse responsible for general care for qualified 
nurses and ensuring continuous professional development. In the context of the discussion focusing on 
minimum training requirements for professional training, they also shared a more general view that many 
potential candidates do not perceive the education towards the profession or the nursing profession itself 
as sufficiently attractive. 

Dental practitioners  

Concerning  dental  practitioners,  the  Commission’s  delegated  powers  are  regulated  by  the  second 
subparagraph of Article 34(2), Article 35(4) and Article 35(5) and cover: a) amending the list of subjects 
in basic study programme as set out in point 5.3.1 of Annex V with a view to adapting to scientific and 
technical  progress;  b)  adapting  the  minimum  period  of  specialist  training  to  scientific  and  technical 
progress; c) and  including in Annex V, 5.3.1 new dental specialties.  When enquired about  the potential 
extension of the delegated powers, some stakeholders expressed strong support for regularly updating all 
minimum  training  requirements  via  delegated  acts.  Other  stakeholders  also  see  the  potential  for 
harmonisation and modernisation of dental education through delegated acts but stress the need for clear 
stakeholder  consultation  mechanisms  if  delegated  acts  are  used.  Several  stakeholders  take  a  middle 
ground:  they  support  technical  updates  via  delegated  acts  (e.g.,  training  subjects,  knowledge  lists)  but 
oppose using them for structural elements like duration or location of training. This divergence of opinions 
concerning the scope of delegated acts concerns equally minimum training requirements for the basic 
training and for dental specialisations.  

Concerning basic dental training, stakeholders oppose shortening the current minimum duration of five 
years. They advocate for maintaining  the duration to ensure adequate acquisition of clinical skills and 
patient safety (with one competent authority considering six years as an adequate minimum). The main 
concern appears to be that reducing training duration would in the first place affect clinical training, i.e., an 
element  of  the  training  that  is  commonly  perceived  as  key  for  patient  safety  and,  at  the  same  time, 
underregulated. As far as the current minimum of three years for specialist training is concerned, most 
stakeholders find it appropriate. None of the stakeholders advocated for reducing the current level, but 
there was a suggestion to extend the duration of training for certain specialties (e.g., orthodontic training). 

40 On average, CAs seem to converge around 25% of clinical training being carried out in a simulated situation.  

31 

 
 
 
A clear majority of competent authorities support a combination of training subjects and competences in 
the training programme for dental practitioners (Annex V, point 5.3.1). 

Clinical training was mentioned by many stakeholders as central to quality enhancement. At the same 
time,  stakeholders  expressed  concerns  over  current  standards,  or  lack  thereof,  in  various  educational 
institutions in Member States. In this respect they point to studies which reveal significant heterogeneity 
in clinical training across dental schools in the European Union.  

Stakeholders consistently highlight that the current provisions for clinical training in Directive 2005/36/EC 
are insufficiently detailed and that this could be the reason for inconsistent application  across Member 
States. They call for developing standards of clinical training. In their view, it is necessary to require that 
clinical training must involve direct patient care and would welcome a summary statement in Annex V.3.1 
to reflect the importance of clinical training. Concerning the content of the training curriculum, there were 
calls for interdisciplinary modules and interprofessional collaboration. 

Veterinary surgeons 

Most stakeholders agree it would be useful if all minimum training requirements were subject to a regular 
update via delegated acts, arguing that this would allow more regular, flexible and thorough updates.  

They consider that the current minimum length of training in years is still appropriate and that lowering it 
could have an adverse effect on the quality of training and the interest of patients.  

Most competent authorities support the combination of training subjects and competences in the training 
programme for veterinary surgeons (Annex V, point 5.4.1). 

Midwives 

The Commission is empowered to adopt delegated acts to amend the list set out in point 5.5.1 of Annex 
V (training programme for midwives) with a view to adapting it to scientific and technical progress. There 
is no clear preference across stakeholders on whether all minimum training requirements should be subject 
to a regular update via delegated acts, although most are favourable to the possibility of a regular update 
of all minimum training requirements via delegated acts, putting forward arguments related to the need 
for regular, flexible and thorough updates.  

Almost all consulted stakeholders consider that the current minimum length of training in years is still 
appropriate and that lowering it could have an adverse effect on patient safety. The arguments put forward 
are related to the need for high-quality training to provide good patient care, and the potential impact of 
reduction  in  the  minimum  length  of  training  on  patient  safety.  Professional  associations  would  be 
favourable to increasing the current minimum length of training to 4 years.  

As  regards  the  list  of  minimum  activities,  it  is  considered  appropriate  by  coordinators  and  competent 
authorities while some professional associations have indicated that additional activities could be added 
in Art. 42.41  

41 Proposals on activities to be covered include prescription, ultrasound, infertility care, sexual counselling, perinatal mental 
health, surgical care, primary gynaecological care, pain management, breastfeeding counselling, and care in menopause. 

32 

 
 
 
Most competent authorities support the combination of training subjects and competences in the training 
programme for midwives (Annex V, point 5.5.1).  

Pharmacists 

Article  44(2)  of  the  Directive  empowers  the  Commission  to  adopt  delegated  acts  concerning  the 
amendment of the list set out in point 5.6.1 of Annex V (subjects of training for pharmacists) with a view 
to adapting it to scientific and technical progress, including the evolution of pharmacological practice. Most 
stakeholders agree that it would be useful if minimum training requirements were subject to a regular 
update via delegated acts. Those who support such an update put forward arguments related to the need 
for regular, flexible and thorough updates.  

The consulted stakeholders generally agree that the current minimum length of training in years is still 
appropriate and that lowering it could have an adverse effect on patient safety. Regarding the minimum 
hours of theoretical and practical training, they find it adequate, while professional associations emphasise 
the need for more practical training.  

Most  stakeholders  agree  that  the  provisions  related  to  the  6-month  traineeship42  are  still  accurate, 
although professional associations suggest either starting the traineeship from the third year of studies 
or provide for longer traineeships of 12 months during or at the end of the theoretical and practical training. 

As  regards  the  list  of  minimum  activities,  it  is  generally  considered  appropriate,  but  professional 
associations have put forward suggestions for additional activities to be included in it.43  

The  majority  of  both  competent  authorities  and  professional  associations  support  the  combination  of 
training subjects and competences in the training programme for  pharmacists (Annex V, point 5.6.1.)  

Stakeholders have reported that in some cases the minimum requirements are not respected, for example 
as  regards  the duration of traineeships,  and that sometimes it is not clear how much of the practical 
training takes place at a distance. 

Architects 

There is no clear preference across stakeholders on whether minimum training requirements should be 
subject to a regular update via delegated acts. Most  Member States see positively the possibility of a 
regular  update  of  all  minimum  training  requirements  via  delegated  acts,  but  not  the  professional 
association of architects.  

The  majority  of  respondents  consider  that  the  current  minimum  length  of  training  in  years  is  still 
appropriate, and that the current list of minimum knowledge and skills and competences are still adequate.  

The professional association discussed the electronic tool developed in collaboration with the European 
Network of Architects’ Competent Authorities allowing to issue standardised Accompanying Certificates, 

42 Article 44 of the Directive provides that pharmacist training shall also comprise a six-month traineeship in a pharmacy which 
is open to the public or in a hospital under the supervision of that hospital’s pharmaceutical department. 
43 Proposals on activities to be covered include supply of medicinal products in community pharmacies; information and advice 
on  medical  devices  and  medicinal  products;  clinical  risk  management  review;  medication  history;  prescription;  provision  of 
advanced pharmacy services; collaboration with other healthcare professionals; quality assurance; pharmaceutical informatics 
and large data management. 

33 

 
 
 
expressing their preference for this over EPC as they think it reflects better the needs of the profession and 
will be easier to implement. 

4.4 Annex V notifications 

Based  on  Article  21a  of  the  Directive,  each  Member  State  shall  notify  the  Commission  of  the  laws, 
regulations and administrative provisions which it adopts with regard to the issuing of evidence of formal 
qualifications for the professions listed in this article. Such notifications concern the introduction of new 
titles  of  qualifications  to  be  added  to  Annex  V  for  sectoral  professions  benefitting  from  automatic 
recognition, as well as changes to titles already included in Annex V for these professions. Notifications 
must be transmitted through the Internal Market Information System (IMI).44 

Currently, nearly 150 competent authorities of EU/EEA States are registered with active and full access to 
the notification procedure in IMI for the healthcare professions module45, and 120 competent authorities 
are registered with active and full access to the architect profession module.46 In total, slightly more than 
150 notifications (including both substantive and editorial changes) were submitted through IMI in the 
period 2020-2024 for the healthcare professions module, and nearly 50 were submitted for the architect 
profession module in the same period.  

There  is  a  promising  level  of  proficiency  among  competent  authorities  concerning  the  IMI  notification 
process, with more than 90% of respondents confirming that they know how to notify via IMI. Competent 
authorities  emphasise  that  the  ability  to  effectively  use  IMI  is  often  gained  through  internal  training 
sessions  and  knowledge  passed  on  by  national  coordinators.  Generally,  there  is  a  good  collaboration 
between coordinators and competent authorities (for example with regard to coordinators communicating 
new information, deadlines for notifications, and adoption of delegated acts). Competent authorities report 
acquiring their operational knowledge of IMI predominantly through training sessions, written guides, and 
on-spot assistance from national coordinators. 

More than 90% of competent authorities responding to the survey  describe the current notification system 
as  efficient. However,  additional  refinement and support within the system  could further  enhance user 
experience and efficiency. Members of the Group of Coordinators highlight training sessions as an essential 
element to optimise the Annex V notification procedure. They also emphasise the value of recording these 
sessions to ensure business continuity amid staff changes. Additionally, notification manuals and closer 
cooperation  between  competent  authorities  and  the  European  Commission  are  proposed  as  effective 
measures to enhance the efficiency and robustness of the notification process.  

National coordinators would also prefer that the Commission be part of the process of verifying whether 
evidence  of  formal  qualifications  notified  by  Member  States  meet  the  requirements  for  automatic 
recognition. Some of them also point to peer review by Member States, and a few members of the Group 
of Coordinators mention external quality assurance bodies.  

44 The obligation to notify through IMI was introduced following the revision of Directive 2005/36/EC as amended by Directive 
2013/55/EU,  replacing  the  previous  system,  where  notifications  were  made  through  formal  correspondence  via  permanent 
representations of Member States.   
45 The healthcare professions module covers the following professions: doctor of medicine, nurse responsible for general care, 
dental practitioner, veterinary surgeon, midwife, pharmacist 
46 The number of competent authorities also includes horizontal coordinators, i.e. NIMICs and regional coordinators. 

34 

 
 
 
According to Article 21a(4) of the Directive, the Commission can adopt delegated acts to amend Annex V 
to the Directive based on the notifications received from Member States. The Commission cannot on its 
own initiative make any change in Annex V by means of a delegated act. Also, the Commission can only 
amend by means of delegated acts specific points of Annex V, namely, with regard to the updating of the 
titles adopted by the Member States for evidence of formal qualifications and, where appropriate, the body 
which  issues  the  evidence  of  formal  qualifications,  the  certificate  which  accompanies  it  and  the 
corresponding professional title.  So far, the Commission has adopted eight delegated acts under Article 
21a(4) to amend Annex V.47 

In  its special report on the recognition of professional qualifications, the European Court of Auditors48 
emphasised the importance of ensuring that Annex V is updated on a regular basis, ideally once a year 
(i.e. within 12 months from the previous update), to ensure the smooth processing of applications. In its 
assessment and management of notifications, the Commission has noticed that one of the issues that can 
lead to delays in including a qualification in Annex V, is inactivity of Member States, e.g. in relation to 
requests for clarification, requests for additional information or requests for Member States to re-submit 
a notification. Another aspect that can lead to delays concerns administrative procedures related to the 
update of Annex V, e.g. procedures required for the adoption of a delegated act. The European Court of 
Auditors  has  acknowledged  that  the  update  of  Annex  V  currently  requires  a  significant  administrative 
workload. Thus, it should be considered whether more simplified procedures could be introduced to ensure 
efficient and regular updates of Annex V, taking into consideration also technical developments and digital 
solutions, which could reduce current administrative procedures.  

Based on feedback received, national coordinators would be open to consider the introduction of a more 
simplified and effective procedure for updating Annex V, as this could allow for more flexibility and swifter 
updates. Several national coordinators would be willing to further investigate a possibility of a system 
where competent authorities can apply automatic recognition based on qualifications broadcasted by the 
European Commission in the IMI, without having to complete a delegated act procedure. However, they 
underline that all necessary verification procedures and feedback mechanisms must be carried out and 
that a strong legal framework should remain in place. Other national coordinators raise concerns about 
moving away from the delegated act procedure. They underline that legislation must remain accessible to 
all stakeholders, including those without access to IMI (such as citizens and companies), and the need to 
ensure sufficient monitoring by and participation of Member States in the process of updating Annex V. 
Thus,  there  is  a  need  for  a  balanced  approach  that  leverages  digital  innovation  while  preserving 
transparency, ensuring robust verification process both by the Commission services and Member States, 
consultation with stakeholders and accessibility of the information about updated lists of qualifications to 
all interested citizens and stakeholders.  

47 Commission Delegated Decision (EU) 2016/790 of 13 January 2016; Commission Delegated Decision (EU) 2017/2113 of 11 
September 2017; Commission Delegated Decision (EU) 2019/608 of 16 January 2019; Commission Delegated Decision (EU) 
2020/548 of 23 January 2020; Commission Delegated Decision (EU) 2021/2183 of 25 August 2021; Commission Delegated 
Decision (EU) 2023/2383 of 23 May 2023; Commission Delegated Decision (EU) 2024/1395 of 5 March 2024, and Commission 
Delegated Decision (EU) 2025/2187 of 30 July 2025. 
48 https://www.eca.europa.eu/ECAPublications/SR-2024-10/SR-2024-10_EN.pdf (page 41) 

35 

 
 
 
5. Common training principles 
Common  training  principles  were  introduced  as  a  new  element  in  Chapter  IIIA  of  Title  III  of  Directive 
2005/36/EC in 2013. They refer to both common training frameworks (Article 49a) and common training 
tests (Article 49b). Common training principles were introduced to promote a more automatic character of 
recognition of professional qualifications for the professions that do not already benefit from automatic 
recognition,  while  taking  into  account  the  competence of  Member States  to  decide  which  professional 
qualifications are required for the pursuit of a profession in their territory and  define the contents and 
organisation  of  their  systems  of  education  and  training.  Common  training  principles  do  not  introduce 
minimum harmonisation of training requirements as is the case for sectoral professions included in Chapter 
III of Title III.   

5.1 Common training frameworks  

The possibility to establish Common Training Frameworks (CTFs) was introduced with Article 49a of the 
revised  Directive,  as  amended  by  Directive  2013/55/EU.  CTFs  are  a  means  to  extend  the  system  of 
automatic recognition based on common sets of minimum knowledge, skills and competences. To establish 
a CTF, the conditions outlined in Article 49a(2) must be fulfilled.49 

Since the inclusion of CTFs in the Directive, several professional organisations have expressed an interest 
in establishing a CTF. However, the assessment has shown that in most cases, the profession in question 
does not fulfil the requirements set out in the Directive.  

To facilitate the assessment of whether candidate professions fulfil the conditions, a Sub-Group on CTFs 
was established in March 2024.50 The Sub-Group plays an important role in analysing national training 
and  education  requirements  for  professions  and  thus  facilitates  the  identification  of  professions  that 
constitute  relevant  candidate  professions  for  which  CTFs  could  be  established.  Currently,  efforts  are 
concentrated on exploring the feasibility of a CTF for the profession of physiotherapist —a profession with 
significant cross-border mobility.    

The Group of Coordinators has highlighted several other professions as potential candidate professions 
for  the  establishment  of  a  CTF,  including  mountain  guides,  engineers,  assistant  nurses,  psychologists, 
occupational therapists, optometrists, teachers, and electricians/electrical installers. In order to identify and 
promote  potential  candidate  professions  for  CTFs,  the  Commission  will  undertake  a  study  in  2026  to 
systematically analyse professions based on set criteria, highlighting those with prospects for successfully 
establishing a CTF. The Group of Coordinators has also provided input on whether the current conditions 
included in Article 49a are suitable for establishing a CTF. A substantial majority (80%) of respondents of 
the Group of Coordinators affirmed the suitability of the existing conditions.  

While  no  CTFs  have  been  established  yet,  the  concerted  efforts  by  the  Commission,  the  creation  of 
dedicated Sub-Groups, and future planned studies reinforce a proactive trajectory towards unlocking their 

49 Among other conditions, the CTF must enable more professionals to move across Member States, the profession must be 
regulated in at least a third of Member States, shall be based on European Qualifications Framework (EQF) levels and must be 
based on existing commonalities among at least a third of Member States in relation to knowledge, skills, and competences.   
50https://ec.europa.eu/transparency/expert-groups-register/screen/expert-groups/consult?lang=en&groupID=104772  

36 

 
 
 
potential, aiming for an increased use of CTFs with a streamlined and structured approach to the selection 
and assessment of candidate professions.  

5.2 Common training tests  

The possibility to establish Common Training Tests (CTTs) was introduced with Article 49b of the revised 
Directive, as amended by Directive 2013/55/EU. CTTs are a means to extend the system of automatic 
recognition  to  new  professions  based  on  a  standardised  aptitude  test.  At  present,  a  CTT  has  been 
established for one profession:  ski instructors.  The profession  of ski instructor stands out as  the most 
mobile regulated profession for temporary mobility in the EU with more than 12.000 cases of temporary 
and occasional service provision across borders declared by competent authorities in the period 2018 to 
2023. 

The CTT for ski instructors was introduced in 2019 with Delegated Regulation (EU) 2019/907.51 IMI is used 
to record and verify whether a ski instructor has passed the CTT.  In the period 2020 to 2024, more than 
2.000 records of completion of CTTs for ski instructors were logged in the IMI. In 2025, the Commission 
services developed a new IMI module to enable Member States to notify changes to the list of qualifications 
giving access to the CTT.  

Since  only  a limited  number of Member States  participate in the framework, the response rate  to the 
survey questions on this topic was accordingly lower.   While most of the Member States that did respond, 
send  notifications,  ,  challenges  such  as  incomplete  information  and  insufficient  inter-state  cooperation 
remain. Member States have recommended enhancing digital support to IMI's role in CTT processes, with 
an emphasis on improved information sharing about upcoming tests and dissemination of results.  

regards 

fees,  whereas  most  Member 

As 
survey 
report none, Italy charges around € 30 fee. The duration of the recognition process ranges from 1 to 90 
days, indicating variation in efficiency across Member States.  

responded 

States 

that 

the 

to 

In the recognition process, Member States generally require applicants to submit their qualifications as 
listed in Annex I of the Delegated Regulation. Additionally, they may request supporting documents such 
as professional insurance, a criminal record check, a medical certificate, and proof of legal establishment 
as a ski instructor. Inclusion in the IMI database typically requires signed data protection information and 
proof of CTT test completion. In some cases, identity documents and other certificates, such as passing of 
the  Eurotest  or  Eurosecurity  test  certificates  are  also  required,  in  line  with  Article  8  of  the  Delegated 
Regulation. 

With regard to the CTT  for ski instructors,  Member States emphasised the need for clearer guidelines, 
notably on exemptions based on Article 6(1)(a) of the Delegated Regulation. The lack of harmonisation in 
national procedures, including varied deadlines, entry forms, and fee structures, creates administrative 
challenges.  Member  States  indicate  that  a  unified  tests  calendar  and  standardised  protocols  across 
Member States could streamline these processes.  

In  2024  and  2025  Commission  services  experienced  an  increased  number  of  requests  related  on  the 
clarification on the application of the Delegated Regulation, especially related to the organisation of the 

51 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02019R0907-20230518  

37 

 
 
 
tests. Given the nature of the profession, the Delegated Regulation relies on cooperation among Member 
States for its correct application. The Commission services have already provided national authorities with 
a document on frequently asked questions for the application of the Delegated Regulation and will consider 
drafting further guidelines.  

Feedback from Member States also concerned specific provisions related to the Technical Test included in 
Part I of Annex II to the Delegated Regulation. Member States suggested further that the reduction in 
corrective coefficients over the years has inadvertently increased the difficulty of the Technical Test, limiting 
market access, and underlined the need for clearer definitions within the Safety Test, included in Part II of 
Annex II to the Delegated Regulation, to promote uniformity across Member States. 

6. European Professional Card 

6.1 Functioning and current use 

The  European  Professional  Card  (EPC)  is  an  electronic  procedure  that  simplifies  the  recognition  of 
professional  qualifications  within  the  EU  for  certain  regulated  professions.  It  offers  professionals  an 
alternative,  fully  digital  route  to  have  their  qualifications  recognised,  simplifying  and  speeding  up  the 
traditional recognition procedure. The tool allows applicants to submit their documents through their home 
country’s  competent  authority  and  benefit  from  the  principle  of  tacit  recognition  if  deadlines  are  not 
respected by the host Member State.   

The EPC was introduced through the modernised Professional Qualifications Directive, specifically Directive 
2013/55/EU, which amended Directive 2005/36/EC. The legal framework for the EPC is set out in Articles 
4a  to  4e.  The  EPC  is  supported  by  a  dedicated  workflow  in  IMI.  The  EPC  module  provides  structured 
interfaces  allowing  professionals  to  submit  applications  online,  upload  documents  and  track  progress. 
Technical  and  procedural  details  are  further  specified  in  Commission  Implementing  Regulation  (EU) 
2015/983, while the processing of personal data in connection with the EPC follows the rules laid down in 
the IMI Regulation (EU) 1024/2012. One of noteworthy procedural aspects of the EPC process that differ 
from the regular recognition process is that the preliminary verification of documents of the applicants is 
done by their Home Member State competent authorities. 

The EPC represented a step towards digitalisation and simplification in the recognition of qualifications to 
access regulated professions across the EU. The EPC currently applies to a limited number of professions— 
nurses,  physiotherapists,  pharmacists,  real  estate  agents  and  mountain  guides—  and  feedback  from 
competent authorities has signalled that it has helped facilitate recognition for mobile professionals in 
specific sectors.  

Feedback gathered through targeted consultation for this Implementation Report highlights that despite 
its potential, the EPC’s impact remains constrained by a range of operational and systemic challenges. A 
recurring  concern  among  Member  States  relates  to  the  complexity  and  rigidity  of  the  IT  system 
underpinning the EPC, which is often seen as cumbersome by both authorities and applicants. Users find 
document  uploads  time-consuming,  navigation  unintuitive,  and  burdensome  in  comparison  to  national 
procedures. Several authorities called for improved user interfaces and more efficient workflows to ease 
the process for applicants and competent authorities alike. Member States consistently pointed to the need 

38 

 
 
for  greater  flexibility  with  deadlines.  Many  authorities  described  difficulty  adhering  to  rigid  automatic 
timeframes, especially when additional documentation or further verifications were required.  

In  this  regard,  some  of  the  criticism  of  the  users  may  relate  to  the  deadlines  and  other  procedural 
requirements  stemming  directly  from  the  amended  Directive  2005/36/EC  or  from  Commission 
Implementing  Regulation  (EU)  2015/983,  rather  than  the  functioning  of  the  IMI  system.  Suggestions 
concerning alerts  for upcoming deadlines and unread messages—to ensure key steps are not missed have 
already been implemented in IMI. As argued by some authorities, such alerts could prevent unintentional 
tacit recognition where action was delayed due to technical or communication issues.  

Moreover, the interpretation of requirements across Member States remains inconsistent, due to flexibility 
of  the  legal  provisions  behind  the  procedure  (no  harmonisation  on  EU  level).  Authorities  pointed  to 
divergent understandings of what documents are necessary, what constitutes “good standing,” or even the 
correct professional title to be used in host Member States. Some Member States suggested the creation 
of a shared EU-level database of accepted documents and interpretations, paired with practical guidance 
materials to support competent authorities in dealing with standard and exceptional cases. Despite its 
benefits, low awareness among potential users as well as limited number of professions currently covered 
by  the  procedure  remain  persistent  barriers  to  the  EPC’s  uptake.  Several  authorities  reported  that 
professionals are often unaware of the EPC as an available option and recommended stronger promotional 
efforts by national authorities and the Commission, alongside its positioning as the preferred application 
channel.  

The following paragraphs examine the implementation of the EPC in two professions, one under the system 
of automatic recognition based on minimum training conditions (general care nurses) and one under the 
general system (mountain guides).  

General care nurses 

Although the EPC is available for general care nurses as one of the sectoral professions, its practical use 
remains limited. Among Member States that provided input, the vast majority indicated that the EPC is 
used only occasionally. Use of the EPC depends on whether the applicant is aware of this possibility and 
informed  about  it  by  the  competent  authority.  The  advice  offered  to  applicants  regarding  EPC  for  the 
profession of general care nurse varies markedly across the Union. A majority of responding countries 
stated that they do not recommend the EPC to applicants as an alternative recognition procedure.  

The  reasons  for  not  recommending  EPC  appear  to  be  related  to:  alleged  lack  of  added  value:  some 
authorities stress that the outcome of the electronic recognition process under EPC does not confer any 
additional  rights  to  the  applicants  in  comparison  with  the  standard  recognition  process  (such  as 
professional  registration  or  the  right  to  practise);  perceived  process  complexity  or  inefficiency:  some 
authorities indicate that in their view the EPC is more administratively burdensome and slower than the 
standard application process; timing and procedural sequence: applicants have often advanced with the 
standard process so that the EPC would not be useful by the time it is suggested.  

However, one of the clearest benefits of the EPC procedure is its short processing time. Based on the survey 
of competent authorities, more than 60% of Member States complete recognition procedures within less 
than  one  month,  while  the  remainder  report  timeframes  of  1–2  months.  No  Member  State  reported 
durations exceeding 2 months.  

39 

 
 
As regards fees, in half of the Member States, EPC and non-EPC fees are the same. In roughly quarter of 
the Member States , EPC applications appear to be more expensive than standard recognition applications, 
and in the remaining quarter of the Member States, EPC applications are cheaper than the standard ones.   

Several  Member  States  reported  technical  or  procedural  difficulties  in  processing  EPC  applications  for 
nurses:  problems  with  users  selecting  incorrect  professional  titles  or  recognition  routes  (automatic  vs. 
general),  leading  to  processing  errors  that  cannot  easily  be  corrected;  frequent  incompleteness  in 
application files and divergent interpretations of required documentation; difficulties with the IMI interface, 
especially when transferring or uploading documents; EPC requests often reaching authorities close to their 
expiry dates, limiting time for assessment; issues with cooperation between competent authorities which 
limit the ability to comply with the  deadline to accept applications; complications in case of third-country 
nationals who are family members of EU citizens. 

Feedback from respondents highlighted several recommendations for improving EPC implementation, such 
as  improvements  to  the  IMI  system’s  usability;  more  consistent  understanding  of  documentation 
requirements and better information-sharing between home and host authorities; and better promotion of 
the EPC among both applicants and administrative personnel.  

Despite mixed experiences, a number of Member States support the expansion of the EPC to other sectoral 
professions, including medical doctors, dentists, midwives, and other health sector professions. 

Mountain guides 

The EPC procedure for mountain guides has been implemented across several Member States, but actual 
usage rates differ significantly among Member States. It appears that the usage rate in some Member 
States  is  close  to  100%  while  low  or  very  low  usage  was  reported  in  the  Member  States  where  the 
profession is economically not relevant (which is often correlated with no professional regulation and so no 
obligation  to  obtain  recognition  of  qualifications  before  practicing  professional  activities  in  this  field).  
Consequently,  incoming  EPC  applications  are  not  processed,  although  advice  may  still  be  provided  to 
outgoing professionals. 

Among countries where the EPC is in use, advice to applicants is generally proactive. Authorities in some 
Member  States  even  reported  that  they  “always”  recommend  use  of  the  EPC  for  mountain  guide 
recognition. However, some divergence appears in Member States where the EPC is less commonly applied. 

The average reported duration for EPC procedures in the mountain guide profession is between one and 
two  months,  with  most  countries  reporting  timeframes  of  less  than  one  month  or  1–2  months.  Fee 
practices are generally neutral or favourable to EPC applicants: most countries either apply no fees or 
maintain equal fee levels across EPC and non-EPC applications. 

Several Member States reported practical obstacles in using the EPC for mountain guides, although the 
degree and nature of these challenges vary:  

-  Difficulties related to recognition of specialised sub-qualifications, such as police mountain guides. 

Suggestions included further harmonisation of qualification categories;  

-  Process  too  complicated,  both  for  applicants  and  authorities,  particularly  due  to  unclear 

establishment status and varying host country demands;  
Lack of consistency in required documents;  

- 

40 

 
 
-  Occasional  problems  when  requesting  additional  documentation  from  home  Member  State 

authorities, particularly for applicants from non-EU or CEE countries;  
Frequent confusion between the mountain guide and mountain leader professions;  

- 
-  Challenges with curriculum alignment, making successful EPC issuance difficult and sometimes 

prompting applicants to abandon the process. 

Respondents offered a range of concrete proposals to improve EPC functionality for mountain guides:  

-  Permission  to  delete  expired  documents  from  EPC  applicant  profiles,  facilitating  smoother 

reapplications;  

-  Unified user interface across all Member States, where applicants could upload documents once 

and designate their destination countries;  

-  Simplification of the process and reduction of administrative burdens, especially for professions 

not regulated in the home Member State;  

-  Better communication and harmonised understanding among competent authorities;  
- 

Enhancing  the  EPC  extension  mechanism,  citing  cases  where  applicants  mistakenly  assumed 
automatic extensions without regard for processing timelines;  

-  Clarification and alignment of titles to avoid confusion between similar professions (e.g. mountain 

- 

guide vs. mountain leader);  
Extension of the EPC to other mountain-related professions, such as aspirant mountain guides 
and medium-mountain leaders. 

6.2 Future implementation 

Despite its uneven implementation, many Member States view the EPC as a promising model for digital 
cross-border procedures in the Single Market. Some underlined the benefits of a structured, secure system 
for  document  exchange  between  competent  authorities,  enabling  faster  decisions  and  clearer 
responsibilities. Others recognised the EPC as helping to accelerate recognition, improve legal certainty for 
applicants, and strengthen cooperation between Member States. 

Those supporting expansion proposed extending the EPC to additional regulated professions, especially 
those  with  high  mobility,  such  as  doctors  and  other  professions  with  harmonised  minimum  training 
requirements. There were countries highlighting the EPC’s role in facilitating mobility and labour market 
integration.  

Member States emphasised further the opportunity to integrate the EPC with the European Digital Identity 
Wallet, providing professionals with a single, secure gateway to present their credentials across borders. 
This could further reduce administrative burdens and improve citizens’ access to services across the EU. 

7. Temporary provision of services 
The  provision  of  temporary  services  across  Member  States  is  an  integral  aspect  of  the  Professional 
Qualifications Directive, facilitating the free movement of professionals within the EU. According to the 
Directive, professionals who are legally established in their home Member State can provide services on a 
temporary  and  occasional  basis  in  another  Member  State  without  the  need  for  prior  recognition  or 

41 

 
 
verification of their qualifications, except for checks according to Article 7(4) in specific cases concerning 
public health or safety. 

7.1 Temporary and occasional activity 

The  Court  of  Justice  of  the  EU  has  consistently  held  that  the  distinction  between  establishment  and 
provision of services needs to be made on a case-by case basis, taking into account four criteria: duration, 
regularity, periodicity and continuity of the activity. The temporary nature of an activity does not preclude 
the provider of services from acquiring, in the host Member State, a certain infrastructure in so far as such 
infrastructure is necessary for the purposes of performing the services in question.52  

Most of the consulted competent authorities indicated in the survey that they do not apply specific criteria 
or  time  limits  and  assess  the  temporary  or  occasional  nature  of  an  activity  on  a  case-by-case  basis. 
However,  some  authorities  reported  using  as  criteria  the  duration  or  frequency  of  the  activity  or  the 
existence  of  an  office  as  indicators  of  establishment  and  requesting  service  providers  to  specify  the 
intended length and frequency of their service provision at the time of declaration.  In this regard, it is 
important to note that the Directive does not include such information in its exhaustive list of required 
documents  and  information  for  declarations  related  to  temporary  service  provision  (Article  7).  Service 
providers, despite their clear intention to operate on a temporary or occasional basis in the host Member 
State, cannot reasonably be expected to predict the exact frequency or duration of their services a year in 
advance. 

During the Group of Coordinators meeting in October 2024, a dedicated discussion took place regarding 
the practical experiences of assessing the temporary and occasional nature of services. Some Member 
States  expressed  difficulties  with  the  case-by-case  assessment  process,  citing  challenges  in  gathering 
comprehensive  evidence  of  all  activities  conducted  by  a  professional  across  the  EU.  There  was  also 
uncertainty about the extent to which competent authorities can verify whether an activity qualifies as 
temporary and occasional service provision, for example as regards requests for documents, ID checks, 
proof  of  physical  presence,  frequency  of  activities,  and  whether  the  home  Member  State  should  be 
consulted. While some Member States have developed specific guidance for certain professions, others 
suggested that the Commission or the Group of Coordinators could create more comprehensive guidelines. 
The uncertainty around the nature of activities under EU law also poses challenges for service providers, 
who often struggle to determine the appropriate rules to apply, leading to operational uncertainties.  

7.2 Prior checks  

Under Title II of the Professional Qualifications Directive, the general rule is that Member States cannot 
impose  restrictions  related  to  professional  qualifications  on  professionals  who  are  already  legally 
established in their home Member State to practice their profession. At most, they may request a prior 
declaration that includes the information and supporting documents exhaustively listed in Article 7. As an 
exception, and in limited cases, Article 7(4) of the Directive allows the host Member State to conduct a 
prior check of professional qualifications for incoming service providers. Such a prior check, which could 
take up to three months, can significantly hinder the free movement of services. Therefore, Article 7(4) 

52 Case C-55/94, Reinhard Gebhard v Consiglio dell'Ordine degli Avvocati e Procuratori di Milano, ECLI :EU:C:1995:411, para. 27 ; 
Case  C-215/01,  Schnitzer,  ECLI :EU:C:2003:662,  para.  28 ;  Case  C-502/20,  TP  v  Institut  des  Experts  en  Automobiles, 
ECLI :EU:C:2021 :678, para.36. 

42 

 
 
 
permits  this  check  only  if:  the  profession  has  public  health  or  safety  implications;  the  prior  check  of 
qualifications aims to prevent serious harm to the health or safety of the service recipient; serious harm 
could  result  from  the  service  provider's  lack  of  professional  qualifications;  and  the  check  is  no  more 
extensive than necessary for this purpose. Professionals benefiting from automatic recognition based on 
qualifications listed in Annex V or professional experience (Annex IV) are exempt from such checks. 

However, data from the Regulated Professions Database indicates that Member States have been imposing 
prior checks even for professions which go beyond the scope of Article 7(4). In response, the Commission 
encouraged Member States to fulfil their reporting obligations under Article 59(2) of the Directive and 
provide specific justifications in the database for each profession subjected to prior checks. The absence 
of such justifications was addressed in a first batch of infringement cases concerning the transposition of 
the Directive. As a second step, the Commission utilized the Single Market Enforcement Taskforce53 (SMET) 
to urge Member States to review the 7(4) professions they had notified in the database and reassess the 
necessity  of  prior  checks.  In  2023,  Member  States  screened  around  800  of  the  1200  prior  checks  as 
reported in the database of regulated professions and agreed to eliminate more than 300 of these. 54 As 
a third step, in December 2024, the Commission initiated infringement procedures for unjustified prior 
checks  of  qualifications,  covering  approximately  300  professions  in  construction,  transport,  business 
services,  and  some  miscellaneous  fields.55  The  Commission  is  currently  reviewing  the  Member  States' 
responses to determine the need for any further actions. 

7.3 Declaration and fees  

Apart  from  professions  with  public  health  and  safety  implications,  the  Directive  does  not  allow  host 
Member States to impose a prior check of professional qualifications for temporary service provision. The 
Directive allows host Member States only to request a simple yearly prior declaration from the service 
provider,  containing  specific  information  as  outlined  in  Article  7.  Once  this  declaration  is  made,  the 
professional can immediately commence providing services without any prior approval process. Since, in 
such a case, there is no recognition procedure involved, and any potential registration with professional 
associations should be automatic as provided in Article 6 on the basis of the prior declaration sent, no fees 
can be charged to incoming service providers. Similarly, imposing a fee for renewing a declaration is also 
unwarranted. 

Under Articles 6 and 7 of the Directive, no fee can be charged to service provider on the basis of the prior 
declaration. Based on the input received, 5 out of 22 reporting competent authorities indicated that they 
impose fees in the context of a prior declaration for temporary service provision. In most cases these seem 
to be linked to a prior check of qualifications procedure. In Finland, for example, the fee exceeds 200 EUR, 
according to the information provided. One-third of competent authorities charge the same fee as for the 
initial declaration procedure. Stakeholders report that individuals seeking temporary or project-based work 
face significant costs and administrative delays, exacerbated by limited support and incomplete digital 
recognition systems. 

53 https://ec.europa.eu/internal_market/smet/index_en.htm  
54 smet-report-2023_en.pdf 
55 https://ec.europa.eu/commission/presscorner/detail/ov/inf_24_6006  

43 

 
 
 
8. Administrative cooperation 

8.1 Alert mechanism  

The IMI alert mechanism under the Directive was put in place in January 2016 and has been used by 
Member State authorities since this date. Alerts originate from competent authorities in one Member State 
and are addressed to competent authorities in all other Member States. The European Commission is not 
involved as a sender, recipient or controller in the information exchanges. However, the Commission is the 
provider of IMI, which serves as the platform for information exchange between Member State authorities.  

Placing an alert 

The sending of alerts through IMI is the responsibility of Member States. However, it is dependent on the 
preceding decision by national authorities or courts restricting or prohibiting, even temporarily, pursuit of 
the specific professional activities listed in Article 56a of the Directive. It follows that while each relevant 
‘restriction’ or ‘prohibition’ needs to be notified in IMI through the alert mechanism, it is up to Member 
States to decide which situations would trigger ‘restriction’ and ‘prohibition’ in the first place. In the period 
2020-2024, more than 38.000 alerts were sent by Member State authorities.  

IMI enables authorities to send alerts for a specific profession or category using different modules. As in 
previous years, in the period of 2020-2024, almost all alerts were sent for cases where a professional 
was restricted or prohibited from practising the profession.  Only very few alerts concerned the use of 
falsified diplomas. The chart below shows the distribution of alerts among the various modules in the 
period analysed.   

Since the reasons for restrictions or prohibitions from practising the profession in Member States may vary 
significantly, IMI enables the national authorities to label an alert as  triggered by ‘substantial reasons 
concerning the practice of the profession’ or ‘other reasons’. The latter type of alert also comprises cases 
in which a professional is for example suspended from exercising the profession for administrative reasons. 
As a result, some alerts may concern events which are not related to a professional malpractice or to 
events that could potentially put into question the safety of patients and recipients of services.56  

56 For example, the events triggering a restriction or prohibition in certain Member States may be: lack of renewal of the licence 
to practice; non-paid professional fees; a voluntary waiver of the licence to practice; a break in practice for a period of 6 months, 
or related administrative shortcomings (e.g., a lack of evidence of continuous practice). The categorisation  of an alert by a 
Member States does not have legal consequences on the validity of the alert, and it does also not pre-determine the effect of 
the alert in other Member States. However, the categorisation gives the authorities in these Member States an early indication 
of the type of event that triggered the alert. 

44 

 
 
 
Alerts sent using the specific modules by all Member States (2020-2024), Source: IMI  

In the period 2020-2024, around 43% of alerts were labelled by Member States authorities as based on 
‘substantial reasons concerning the practice of the profession’ while around 57% concerned ‘other reasons’.  

The categorisation of alerts has been addressed by the Court of Auditors in its report on the recognition 
of professional qualifications from 2024.57 In this report, the Court of Auditors notes that “currently, there 
is no formal legal definition of a substantial reason, and it is up to the member states to assess what is 
included: misconduct, ongoing disciplinary measures, or criminal convictions.” This finding resulted in the 
Court’s recommendation for the Commission to “clarify, such as by means of an implementing act, the 
concept of ‘substantial reasons’”.  

In  2020,  a  significant  majority  of  the  alerts  were  sent  by  competent  authorities  in  the  UK.  After  the 
withdrawal of the UK from the EU, as of 2021, Italy was the Member State sending the highest number 
of alerts accounted for about half of the total number of alerts sent. On the other hand, there are Member 
States that do hardly send any alerts. For example in several Member States, the total number of alerts 
in  the  period  2020-2024  has  been  10  or  lower  (i.e.,  maximum  two  alerts  per year  for  these  Member 
States). 

57 https://www.eca.europa.eu/en/publications/SR-2024-10&od=1  

45 

 
 
 
 
Alerts sent by IMI module and reason (2020 –2024), Source: IMI 

The differences in the number of alerts encoded in the system could only to a certain degree be explained 
by the size of the Member States and the number of professionals per Member State. As mentioned above, 
a much more significant factor appears to be the existence and the application of measures resulting in 
the temporary suspension of the professional’s right to exercise the profession. That is why Member States 
which routinely apply such temporary measures, e.g., in cases where the professionals fail to document 
the  completion  of  mandatory  training,  produce  a  higher  number  of  alerts  compared  to  other  Member 
States. The following chart shows the number of alerts issued by Member States’ authorities (Member 
States not having issued any alerts are not in the chart). 

46 

 2020 2020 Total 2021 2021 Total 2022 2022 Total  Substantial reasons % of alerts sent for substantial reasons Other reasons (e.g. administrative reasons)  % of alerts sent for Substantial reasons % of alerts sent for substantial reasons Other reasons (e.g. administrative reasons)  % of alerts sent for Substantial reasons % of alerts sent for substantial reasons Other reasons (e.g. administrative reasons)  % of alerts sent for other reasons other reasons other reasons Doctors  1,731 78% 494 22% 2,225 544 38% 893 62% 1,437 665 73% 241 27% 906 Education of minors  261 83% 55 17% 316 75 71% 30 29% 105 60 49% 63 51% 123 Nurses  2,232 72% 883 28% 3,115 2,746 65% 1,478 35% 4,224 2,279 52% 2,073 48% 4,352 Other health professions  1,531 57% 1,142 43% 2,673 337 22% 1,213 78% 1,550 368 8% 4,111 92% 4,479 Veterinary surgeons and veterinary nurses  24 44% 30 56% 54 16 3% 520 97% 536 29 2% 1,326 98% 1,355 Total 5,779 69% 2,604 31% 8,387 3,718 47% 4,134 53% 7,853 3,401 30% 7,814 70% 11,218   2023 2023 Total 2024 2024 Total 2020-2024 2020-2024  Substantial reasons % of alerts sent for substancial reasons Other reasons (e.g. administrative reasons)  % of alerts sent for Substantial reasons % of alerts sent for substancial reasons Other reasons (e.g. administrative reasons)  % of alerts sent for Substantial reasons % of alerts sent for substancial reasons Other reasons (e.g. administrative reasons)  % of alerts sent for other reasons other reasons other reasons Doctors  920 95% 47 5% 967 1,055 64% 595 36% 1,650 4915 68% 2270 32% 7,185 Education of minors  55 59% 39 41% 94 56 81% 13 19% 69 507 72% 200 28% 707 Nurses  348 15% 2,039 85% 2,387 373 20% 1,523 80% 1,896 7978 50% 7996 50% 15,974 Other health professions  372 24% 1,175 76% 1,547 437 29% 1,061 71% 1,498 3045 26% 8702 74% 11,747 Veterinary surgeons and veterinary nurses  19 18% 85 82% 104 20 4% 524 96% 544 108 4% 2485 96% 2,593 Total 1,714 34% 3,385 66% 5,100 1,941 34% 3,716 66% 5,659 16553 43% 21653 57% 38,206   
 
 
 
Alerts sent per Member State (2020-2024). Source: IMI. 

*) Figures for United Kingdom are reported only for the period until the withdrawal of the United Kingdom from the EU. 

Alerts sent by Member States (2020 –2024), Source: IMI 

Significant differences in the number of alerts sent by Member States are a genuine matter of concern. It 
is therefore necessary to consider whether Member States can further harmonise their approach as to 
when to send alerts and how to categorise alerts. It does not appear to be reasonable to require that 
Member States provide more specific information in the alert than already required (as this could lead to 
even more reluctance to place alerts). However, it should be easier for Member States authorities to clearly 
establish the background for an alert through further exchange of information in IMI with their counterparts 
in other Member States. For this reason, in addition to addressing the recommendation from the Court of 
Auditors  concerning  the  categorisation  of  alerts,  the  Commission  services  intend  to  consider  further 
improvements to the Alert modules of the IMI system as well as developing guidelines for users regarding 
alerts. The Commission has already initiated discussions with Member States. 

Following up on an alert  

The Alert Mechanism tool in IMI is offered by the Commission to facilitate the exchange of information 
between  Member  States  on  alerts  that  can  further  contribute  to  preventing  unfit  and/or  fraudulent 
professionals from moving freely and endangering public health, safety, and mutual trust across borders. 

47 

 
 
For it to be effective, it is essential that competent authorities in Member States actively make use of 
alerts placed in IMI by other Member States. 

It is the Member States’ competence (right and/or responsibility) to verify if the applicant is fit for practice 
of the profession on its territory.  In this regard, the IMI system is designed to support various types of 
checks  that  can  be  done by  Member  States  in  various  situations.    For  example,  a  Member  State  may 
perform checks when processing individual applications for recognition of professional qualifications to 
double-check  documents  from  the  home  Member  State,  demonstrating  that  a  professional  is  not 
suspended or prohibited from pursuing their profession. However, IMI can also be used to make ad hoc or 
regular checks of other individuals pursuing activities in a Member State or ad hoc or regular checks of 
new alerts.  

The information collected from the Member States  suggest that national authorities indeed developed 
various ways of using the alert mechanism. For example, some of them declare that they regularly check 
new alerts against their professional registers. Other authorities do not make such checks, and they consult 
IMI  alerts  when  a  professional  seeks  recognition  of  professional  qualifications.  The  difference  in  the 
approach often stems from the differences in the national legislation concerning the impact of prohibitions 
or restrictions imposed in other Member States on the right to pursue the profession in the Member State 
concerned, the practices developed in this regard or the availability of resources to do the checks. For 
example, some Member States reported that they do not have a valid mechanism for opening a ‘case’ (and 
potentially applying a restriction or prohibition) against a professional who committed an act outside that 
Member State, for which they are prohibited or restricted in pursuing professional activities. 

In  this  regard,  the  Court  of  Auditors  noted  in  its  report  that  in  the  current  legal  status  quo,  “it  is  not 
mandatory for competent authorities to consult the alert module for substantial reasons before taking a 
[recognition] decision”. The Court of Auditors suggested that “due to the high number of alerts”, authorities 
in several Member States did not check them when reviewing individual applications. The Court of Auditors 
recommended the Commission to “make it obligatory for member states to use the alert mechanism under 
the Internal Market Information System during the recognition procedures, ensuring that alerts received for 
substantial reasons are treated appropriately.”  

In  its reply to the report58, the Commission explained that the alert mechanism could be improved by 
providing more context about the underlying reasons to send an alert to make it easier for Member States 
to distinguish cases that require follow up from those that do not (including providing more clarity on the 
concept of “substantial reasons”). The Commission also suggested to provide guidance and to facilitate 
the exchange of best practice on the follow up of alerts. However, as stressed by the Commission in its 
reply, the legal consequences of the alerts remain  the Member States’ competence.  

Consistent, timely and effective follow up to the alerts in host Member States  depends  mainly on  the 
existence of proper legal and organisational national frameworks. Improving  accessibility and quality of 
information provided in IMI is important, however, it cannot replace the effort on the side of Member States. 
Therefore, further improvements of the Alert Mechanism modules in IMI  can be expected to  benefit mainly 
those Member States that already have  strong implementation tools (legal, organisational) in place. 

58 https://www.eca.europa.eu/Lists/ECAReplies/COM-Replies-SR-2024-10/COM-Replies-SR-2024-10_EN.pdf (p. 10)  

48 

 
 
 
8.2 Provision of information 

The  proper  functioning  of  the  system  of recognition  of  professional qualifications  within  the  EU  relies 
fundamentally on the free flow and accessibility of pertinent information across all stakeholders involved 
in the process. Effective comprehension and dissemination of information are critical for ensuring that the 
citizens  derive  maximum  benefit  from  the  rights  conferred  on  them  by  the  Directive  and  its  national 
implementation frameworks. 

Assistance Centres 

Directive  2005/36/EC  establishes  several  measures  to  ensure  stakeholders  are  well-informed  and  can 
easily access pertinent information concerning professional qualifications. One of the pivotal measures is 
the establishment of assistance centres, as outlined in Article 57b. Assistance centres play an essential 
role in the system of professional qualifications recognition by serving as the primary contact points for 
citizens and competent authorities seeking guidance and information.  

During the period covered by this implementation report, the number of requests received by Assistance 
Centres varied widely. Some countries reported high volumes, with the largest receiving over 500 requests, 
while others handled fewer than 50–100 requests per year, reflecting significant differences in demand 
and utilisation across Member States.  

Overall, the general system of recognition generated more issues than the automatic recognition system. 
Key recurring concerns under the general system included: long procedures; high or unjustified document 
requirements; high fees; lack of digital procedures; limited or no choice between compensation measures; 
delays in aptitude tests or adaptation periods; perceived unjustified invocation of substantial differences.  

Under the automatic recognition system Member States reported occasional problems with documentation 
burdens and lack of digital tools. A common concern was the difficulty professionals face in  accessing 
accurate, updated information on recognition procedures in host Member States. This was raised by several 
Member States, pointing to fragmentation in online resources and institutional websites. 

Additionally, a lack of awareness and understanding of the European Professional Card was consistently 
flagged. Respondents from several Member States observed that professionals often do not know the EPC 
exists or how it differs from standard recognition. This undercuts the EPC’s potential to streamline mobility 
in  professions  such  as  nursing  or  physiotherapy.  More  awareness  raising  among  professionals  and 
provision  of  training  for  competent  authorities  on  the  use  of  EPC  by  both  Member  States  and  the 
Commission services seems necessary for the system to function to its full potential. 

The  survey  results  underscore  the  essential  but  strained  role  of  Assistance  Centres  in  helping  citizens 
navigate  recognition  systems.  The  following  areas  of  improvement  emerged  across  Member  States: 
greater  harmonisation  and  clarity  in  recognition  procedures  under  the  general  system;  enhanced 
digitalisation, including full e-submission capabilities and interoperable databases; broader communication 
and guidance on the use and benefits of the EPC; capacity support and resourcing for Assistance Centres 
to  handle  complex  cases,  particularly  where  their  roles  overlap  with  competent  authorities;  improved 
coordination  and  feedback  loops  between  ACs  and  competent  authorities  to  accelerate  resolution  of 
procedural bottlenecks. 

49 

 
 
While some Member States have developed more integrated and visible Assistance Centre services, others 
would benefit from increased visibility and clearer mandates. The findings suggest that strengthening the 
Assistance Centre network would significantly improve the overall user experience of Directive 2005/36/EC 
and contribute to smoother professional mobility across the Single Market. 

Other sources 

In  the  survey  of  citizens,  the  most  reported  source  of  information  was  official  websites—either  of 
competent authorities, ministries, or recognition bodies. Many respondents relied on national portals, while 
others accessed EU-level information such as the European Commission’s Your Europe portal. Professionals 
generally  perceived  these  websites  as  essential  first  points  of  reference.  The  clarity,  accessibility,  and 
comprehensiveness of website content varied significantly between countries and professions. While some 
found the information easy to follow and up to date, others reported that websites lacked detail on required 
documentation, procedural timelines, and fees.  

A number of professionals relied on peer support or advice from colleagues who had previously undergone 
the recognition process. This was particularly common among physicians, pharmacists, and dentists. In 
many instances, informal networks served as substitutes for formal information channels. 

The  survey  included  respondents  from  a  variety  of  professions  in  health-related  fields—particularly 
doctors, dentists, pharmacists, and nurses but there was considerable variation in access to information 
within this group. Medical specialists (e.g. oncologists, surgeons, nephrologists) often expressed that they 
had to consult multiple information sources and that guidance on specialty recognition was limited or 
inconsistent  across  platforms.  In  contrast,  nurses  and  midwives—especially  those  using  the  European 
Professional Card— reported smoother information access, often being able to rely on a single website or 
centralised recognition portal. Pharmacists frequently highlighted ambiguity in recognition criteria across 
Member States. Reliance on both online and personal sources was therefore particularly strong among 
pharmacists. 

Availability and exchange of information  

A recurring theme was the fragmented nature of information between home and host countries. Many 
respondents  sought  information  from  both  ends,  often  receiving  conflicting  or  incomplete  guidance. 
Applicants  regularly  contacted  chambers  or  guidance  services  in  their  home  countries  as  well  as 
destination  country  authorities.  However,  coordination  between  these  entities  appeared  limited.  For 
example,  several  respondents  migrating  to  one  of  the  Member  States  described  the  need  to  consult 
multiple regional bodies,  each with different procedural expectations. This decentralisation adds to the 
administrative burden and generates confusion. Member States with centralised portals or coordinated 
guidance services were more positively assessed by respondents. 

In  some  cases,  the  employer  played  a  key  role  in  facilitating  recognition.  For  example,  some  medical 
professionals mentioned that hospitals had consultants or legal representatives to guide them through the 
process.  In  other  cases,  private  recruitment  agencies—especially  for  nurses  and  doctors—acted  as 
intermediaries,  helping  candidates  prepare  documents,  navigate  language  requirements,  and  ensure 
procedural compliance. While these actors contributed to smoother individual experiences, their use again 
introduces disparities for those without institutional support. 

50 

 
 
Even  when  information  was  accessible,  language  barriers  remained  a  frequent  obstacle.  Respondents 
migrating  to  countries  with  less  commonly  spoken  languages  regularly  highlighted  the  challenge  of 
navigating administrative language. Similarly, the complexity of documentation requirements, particularly 
where  translations  and  certified  copies  were  needed,  was  cited  as  a  recurring  difficulty.  Multiple 
respondents expressed frustration at vague instructions or inconsistent requirements among competent 
authorities. 

A majority of responding countries confirmed that their National Contact Points collect user feedback or 
statistics. In some Member States, feedback tools are integrated into digital platforms, allowing citizens to 
submit comments and evaluations following interactions. Other Member States indicated that feedback is 
collected informally—via phone, email, or direct conversations—without structured analysis. There are also 
Member States which rely on partner institutions to gather user experience data indirectly. The variation 
in practice limits the possibility of comprehensive and comparative performance monitoring across the EU. 

Cooperation between National Contact Points across Member States remains limited and largely ad hoc. 
Some  countries  report only  occasional  engagement, while  others  describe  cross-border  cooperation  as 
rare. A few Member States have recently increased informal exchanges to address recurring issues with 
the recognition of professional qualifications, but this remains reactive rather than part of a structured 
framework. Regional initiatives may offer useful models in the absence of broader coordination at the 
European Union level. Several respondents also noted that data protection concerns hinder cooperation on 
specific  cases  when  formal  protocols  are  lacking.  Interaction  between  National  Contact  Points  and 
competent authorities in other Member States is similarly inconsistent.  

In conformity with the Directive, many countries rely on the Internal Market Information system for cases 
raising justified doubts, and some report rising numbers of requests for information, indicating a growing 
need  for  more  systematic  cooperation.  However,  for  many  countries,  communication  with  competent 
authorities in other Member States remains infrequent and limited to exceptional situations. Overall, these 
patterns suggest that cooperation between National Contact Points and networks of competent authorities 
is still insufficiently developed. 

9. Enforcement 
The enforcement mechanism under Directive 2005/36/EC constitutes a crucial element in ensuring the 
effective and correct application of the Directive across Member States. Given the importance of uniform 
application,  several  Member  States  have  faced  infringement  procedures  due  to  non-compliance  with 
various aspects of the Directive. 

9.1 Overview of transposition  

The transposition of Directive 2005/36/EC represents a pivotal measure in ensuring coherent application 
of  the  procedural  rules  on  recognition  as  well  as  the  minimum  harmonised  requirements  for  sectoral 
professions across EU Member States.  

Almost full transposition has been achieved so far as only a few Member States still need to comply with 
transposition requirements: partial access has been successfully transposed across all Member States and 
only one issue remains  in relation to health professions benefitting from automatic recognition in  one 

51 

 
 
Member State; the provision on mobility from non-regulated Member States, which requires one year of 
professional experience has been almost fully transposed, despite remaining issues in two Member States; 
the alignment of qualification levels has been fully transposed in all Member States except two; rules on 
language controls have been implemented in all Member States except three; the new rules on mutual 
recognition of professional traineeships within the internal market have been implemented in all but one 
Member State.   

For  temporary  service  provision,  challenges  persist  in  seven  Member  States  concerning  excessive 
administrative  requirements  or  incompliant  rules.  Specific  efforts  still  have  to  be  made  to  ensure  that 
unjustified barriers for temporary service provision in another Member State are no longer in place.  

Member States demonstrating partial or incorrect transposition should prioritise rectifying these procedural 
and legal deficiencies to fully align with the provisions of the Directive. This effort will not only enhance 
individual mobility but also strengthen the overall functioning and integration of the Single Market for 
professional services. Enhanced cooperation and information sharing between Member States, supported 
by the European Commission's oversight, will be instrumental in achieving these objectives. 

9.2 Infringement batches of non-compliance with the Directive 

First infringement batch 

In 2019, infringement procedures were ongoing across EU Member States addressing issues around the 
European Professional Card, the alert mechanism, partial access to professional activities, proportionality 
of  language  requirements,  the  establishment  of  assistance  centres,  territorial  restrictions,  and 
transparency obligations.  

•  Main outcomes of the proceedings 

Over the past five years, significant progress has been made to address the issues raised. In the end of 
2024,  infringement  procedures  remained  open  against  only  six  Member  States.  Of  the  original  batch, 
several cases have since been resolved: nine procedures were closed in the years 2020-2022, ten were 
closed in 2023, and one was closed in 2024. 

•  Remaining open issues 

The Commission pursues its dialogue with some Member States for some remaining issues concerning: 

•  Language requirement for teachers where the law 

 restricts which types of language-proficiency proof are accepted and forces systematic language checks 
that do not seem necessary for the teaching profession or the timing when the proof of language skills 
needs  to  be  submitted.  Partial  access,    particularly  concerning  professions  with  automatic  recognition, 
remain unresolve. Further, strict language requirements for schoolteachers  also raises  concerns. These 
involve  the  level  of  language  skills  required  to  practice  the  profession,  the  specific  certificates  to  be 
submitted, and  

• 

Insufficient implementation of the alert mechanism even though the system is active, alerts 
are not adequately notified.  

52 

 
 
•  Compliance with transparency and notifications obligations  

Restrictions to temporary provision of services and territorial limitations for some professions, notably for 
tourist guides. Specifically, the automatic imposition of exams for tourist guides wishing to operate at 
protected sites constitutes a breach of several provisions of the Directive and of general EU law principles. 
The requirements do not only inhibit free service provision but also disregard the need to evaluate foreign 
qualifications equivalently and to offer a choice in compensation measures within a reasonable time frame. 

Second infringement batch 

Infringement  procedures  were  also  engaged  against  EU  Member  States  regarding  freedom  of 
establishment, freedom to provide services, automatic recognition of professions based on harmonised 
minimum training requirements, recognition of professional traineeships, and administrative cooperation. 

•  Main outcomes of the proceedings 

In  the period 2020-2024, the number of unresolved infringement procedures has been reduced: three 
procedures were closed in 2020, four in 2021, nine were closed in 2023, and two more in 2024. In 2025, 
eight Member States continue to face active procedures. 

•  Remaining open issues 

The Commission pursues its discussions with some Member States concerning: 

•  Temporary provision of services for some professions, 
•  The  recognition  process  with  the  lack  of  transposition  of  some  modifications  introduced  with 
Directive 2013/55/EU for specific professions, including the profession of independent childminder 
and nursery director. Challenges also persist in recognising certain alternative qualifications. 
•  Conditions of recognition for specific professions such as the building engineering professions or 
sworn  translators.  Existing  conditions  for  recognition  are  not  aligned  with  the  Directive,  with 
excessive proof requirements for qualifications and professional experience or rules relating to the 
level of qualifications or compensatory measures applied. 
 Minimum training hours for nurses, and specific training rules in general medical practice and the 
procedural requirements imposed on veterinary surgeons.  

• 

•  The application of automatic recognition to specific professions falling under it such as electrical 

contractors and gas installers.  

Court rulings 

The Commission also decided to refer to the Court two infringement proceedings where the Court of Justice 
of the European Union delivered its judgements: 

•  The European Court of Justice's judgement in case C-75/22 of 8 May 202459 brought to light the 
failure of the Czech Republic to adopt provisions necessary to determine the status of persons 
undergoing an adaptation period or wishing to prepare themselves for an aptitude test; provisions 
necessary to enable veterinary surgeons and architects to provide services, within the framework 

59 EUR-Lex - 62022CJ0075 - EN - EUR-Lex 

53 

 
 
 
of the freedom to provide services, under the professional title of the host Member State; and 
provisions necessary to ensure that the competent authority of the host Member State has one 
month to acknowledge receipt of the application for recognition of professional qualifications and 
to inform the applicant of any missing document.  

•  The  Court’  judgement  in  Case  773/22  of  29  July  202460  found  significant  non-compliance  in 
SIovak law on numerous issues. Prior checks on qualifications are not limited to health or safety-
related professions, causing unnecessary barriers;  compensation measures are not confined to 
significantly different matters, resulting in excessive demands; the national law does not ensure 
that midwives are able to gain access to and pursue all the activities described in the Directive, 
potentially restricting practice. Additionally, the Member State requires excessive documentation 
by asking applicants to prove the absence of disciplinary sanctions beyond serious professional 
misconduct,  thus  exceeding  the  Directive's  provisions.  This  can  deter  professionals  due  to 
heightened bureaucratic demands. Lastly, it was found that the Member State has not established 
guidelines  for  recognising  professional  traineeships,  which  can  limit  the  opportunities  for 
professional growth and the integration of new entrants into regulated professions. 

Third batch on Points of Single Contact  

In  2019  the  Commission  also  initiated  infringement  proceedings  against  Member  States  for  non-
conformity  with  requirements  laid  down  in  Directive  2006/123/EC  (Services  Directive)  and  Directive 
2005/36/EC concerning the establishment and functioning of points of single contact (PSC).  

The letters of formal notice pointed out to: lack of information on certain requirements, formalities, and 
procedures; insufficient quality of information, and lack of possibility for users, including cross-border users, 
to access and complete administrative procedures online. The aim of these procedures was not only to 
address  specific  non-compliance  issues  revealed  in  sample  testing  of  Member  States’  PSCs.  The 
Commission also requested Member States to review the areas not addressed directly in the  letters of 
formal notice to ensure full compliance, and to improve their general PSC’s legal frameworks. 

The  corrective  measures  taken  by  Member  States  encompassed  completing  and/or  updating  the 
information published on websites, verifying the functioning of web links, and deploying relevant technical 
ICT solutions related to on-line procedures. Member States achieved considerable progress on access to 
and the quality of information, however, in several Member States, the availability of on-line procedures 
and their accessibility for cross-border users were improving slower than expected. Over time, Member 
States also reported that, in relation to matters covered by the procedures, they focused on implementation 
of Regulation (EU) 2018/1724 (Single Digital Gateway Regulation).61 

In  recognition  of  Member  State’  efforts,  and  with  the  view  to  enable  deploying  resources  for 
implementation of the Single Digital Gateway Regulation and the amended e-IDAS Regulation (Regulation 
(EU) 2024/1183), the Commission  decided that it was not opportune to continue the proceedings  and 
decided to close the infringement procedures in December 2023. 

60 EUR-Lex - 62022CJ0773 - EN - EUR-Lex 
61 The Professional Qualifications Directive sets the substantive rules for recognising professional qualifications, while the Single 
Digital Gateway Regulation requires that clear, user-friendly information related to recognition of professional qualifications be 
available and accessible online. 

54 

 
 
 
Article 7(4) batch 

As mentioned above, the Directive provides the possibility to Member States to conduct prior checks on 
professional  qualifications  only  for  professions  having  public  health  and  safety  implications,  and  not 
benefitting from automatic recognition, in case of temporary provision of services (article 7(4)).  

The  aim  is  to  avoid  any  appreciable  risk  that  a  professional  carrying  out  the  professional  activities  in 
question without the required professional qualifications will result in serious damage to the health and 
safety of recipients of services that could be avoided if a prior check were carried out , while not obstructing 
the free movement of professionals across borders unnecessarily.  

The Commission assessed the justifications provided by Member States for prior checks, with a focus on 
three areas which are of particular importance, namely professional services related to the construction 
sector, the transport sector and business services. It was concluded that for several professions in these 
sectors,  the  conditions  of  the  Directive  were  not  fulfilled,  and  the  Commission  opened  infringement 
procedures against 22 Member States in December 202462.  

9.3 Individual cases 

Finally, over the period from 2020 to 2024, several other infringement procedures were initiated against 
Member States to address specific non-compliance issues, contributing to the overall enforcement efforts. 

A total of 8 procedures were opened against various Member States during this period. By the end of 
2024, five procedures had been closed, while others remain pending resolution.  

One Member State has faced multiple infringement cases in relation to the recognition of professional 
qualifications. One involved the  incorrect  application of the  procedure relating to  academic recognition 
instead  of  recognition  of  professional  qualifications  for  teachers63,  and  another  concerning  excessive 
deadlines for qualification recognition was closed in 2024. 

Portugal faced a pivotal judgement from the Court of Justice on 29 July 2024.64 The case revolved around 
the withdrawal of acquired rights from civil engineers authorised to perform architectural projects under 
the Directive. These professionals, particularly those who started their training before the academic year 
1987/88, had acquired rights under Annex VI which were annulled due to new legislative conditions. These 
conditions were found to be restrictive and non-compliant for engineers trained and established abroad. 
Following the ruling, the Member State is now required to amend its legislation to implement the Directive 
effectively and remove these barriers to professional mobility and practice. 

Resolved and pending cases span across several Member States, targeting issues such as non-conformity 
of  national  legislation  with  different  Directive  provisions.  For  instance,  resolved  issues  covernon-
compliance on lawyer legislation, engineering and architectural professions and recognition of snowboard 
instructor qualifications from other Member States.  

62 December infringements package: key decisions 
63 However, two infringement procedures covering the same issue were still pending at the end of 2024 for other professions. 
64 EUR-Lex - 62022CJ0768 - EN - EUR-Lex.   

55 

 
 
 
Consistent  monitoring  and  evaluation  remain  pivotal  to  support  the  Directive's  aim  of  facilitating 
professional mobility and fostering a functioning Single Market. The following gives an overview of specific 
cases of misapplication that the Commission has become aware of.  

The requirement for Member States to promptly decide on professional qualification recognition within 3 
months of receiving complete documentation for the automatic recognition regime and within 4 months 
for the general system is crucial for enabling free movement of professionals. However, misapplications 
have been found in some Member States who have exceeded the timeframe due to bureaucratic issues 
and unnecessary document requests for several professions and within several sectors. 

The Directive also addresses the conditions under which compensation measures— i.e. adaptation periods 
or aptitude tests—might be required when recognising a professional qualification from another Member 
State  under  the  general  system.  This  article  aims  to  ensure  that  any  additional  requirements  are 
proportionate and only applied where significant differences in training or professional activity exist, thus 
supporting the primary goal of facilitating professional mobility across the EU. However, certain Member 
States create obstacles such as: 

•  Disproportionate compensation measures: Instances have been reported where the imposed 
compensation  measures  do  not  align  with  the  objective  of  proportionality.  For  example,  one 
Member State requires lengthy adaptation periods that exceed reasonable durations, particularly 
for physiotherapists. These excessive requirements can discourage professionals from pursuing 
recognition and limit their mobility. 

•  Lack of choice for applicants: One Member State has been reported to not provide the choice 
between completing an adaptation period or taking an aptitude test in case of positive recognition 
decision with compensation measures for the profession of osteopath. The Directive stipulates 
that professionals should have the option to choose between an adaptation period and an aptitude 
test.65  

•  Delays in organising aptitude tests: Disproportionate waiting time to pass an aptitude test 
has been reported in some Member States, for a number of health professions and the profession 
of accountant, with applicants having to wait more than six months and sometimes years to take 
the test.  

Other issues of incorrect application have also been tackled by the Commission through other channels, 
such as SOLVIT or dialogues with Member States, through which satisfactory results have been achieved. 

10. Insights from professionals and businesses  
In the following paragraphs, we aim to further highlight the perspectives of those who directly rely on the 
Directive—individuals, in particular mobile professionals, and the businesses that employ them. While some 
of these  viewpoints have already been touched upon, the purpose here is to bring them together and 

65 Except for professions falling under the scope of Article 14(3) of the Directive 

56 

 
 
 
provide a  coherent and comprehensive understanding of how the Directive’s implementation has  been 
perceived. 

10.1 Individuals’ views  
While some individuals66 highlight positive aspects – such as smooth and fast recognition procedures as 
well as organised and helpful authorities  – many also emphasise difficulties that make the recognition 
procedure  challenging.  Overall,  they  call  for  reduction  of  bureaucracy  and  digital  solutions  to  make 
applications more manageable.    

One of the main challenges raised by respondents is the length of the procedure – both in relation to the 
general system and automatic system of recognition Many describe long procedures as indicated in the 
chart below, sometimes time limits not being respected. 8.8% of respondents (n=284) are reporting on 
durations of 1 year or more, with several respondents even experiencing a duration of 4 years. Out of 
those Red tape and waiting time to take tests (e.g. language tests) are mentioned among the things leading 
to delays in the process.  

Up to 1 month
12%

Up to 2 months
19%

Up to 3 months
26%

More than 4 
months
28%

Up to 4 months
15%

Respondents that replied on the total length of the procedure for recognition of their EU qualification 
in another Member State (n=284) 

Respondents also flag that the recognition procedures are often costly (with cases of more than 3.000 
EUR),  especially  because  of  document  requirements  (e.g.  when  original  certified  copies  or  certified 
translations are required). Out of the respondents who replied on the number of documents requested for 
recognition of their EU qualifications in another Member State, 21.4% indicated that overall more than 10 
documents were required (n=281). In this regard, they suggest that authorities accept English certificates 
without requiring translation into the national language of the Member State, as translation of documents 
into the language of the host Member States are both time-consuming, costly and require a lot of effort 

66 Based on responses from more than 450 citizens – see footnote 7. 

57 

 
 
 
 
from the professional.  They also suggest having online checklists that list all required documents and 
providing the possibility to submit documents online.     

Fee and costs of 
1000 EUR or 
more
4%

No fees were 
charged
40%

Fee and costs 
below 1000 EUR
39%

Fees were charged 
but the respondent 
did not indicate the 
amount
17%

Respondents that replied on fees and costs (including costs incurred by the applicant) for recognition of their 
EU qualification in another Member State (n=281) 

Many respondents also raise the issue of not receiving clear information or instructions before or during 
the  recognition  procedure.  As  examples,  they  mention  that  instructions  were  given  in  country-specific 
terminology, that they didn’t receive information on the specific steps to be taken, that communication 
was only in the language of the host Member State and that forms to be filled out by the applicants were 
not provided in English. Several respondents emphasize that it would be helpful if information websites 
and guidelines were provided in English. Some respondents also mention that the staff they were in contact 
with during the recognition procedure were not cooperative or helpful, and that the national assistance 
centre for recognition was often unavailable when the applicant tried to reach it by phone.   

When applicants receive negative recognition decisions, they may then take up a job for which they are 
overqualified and in which they receive in the host Member State lower salaries than expected, which may 
later result in them moving back to their home Member State. This also applies to professions in which the 
Member State is experiencing shortages (e.g. medical professions).  

As to medical specialisations, respondents flag frustration with the fact that Member States do not have 
the same specialisations or sub-specialisations, leading to professionals specialised within one field in the 
home Member State having to work in the host Member State in a field which may not exactly reflect their 
expertise. They mention that the medical specialisations listed in the Directive should be updated, as the 

58 

 
 
 
generic names used for the specialisations cause confusion by using outdated terminologies in some cases. 
Others  suggest optimising recognition procedures by making language requirements dependent on the 
specialisation (for example a stricter language requirement for the profession of psychiatrist compared to 
the profession of pathologist).  

In general, respondents also express surprise with the complexity and length of procedures and the lack 
of digital procedures (e.g. some Member States requiring documents submitted in paper format). 68.2% 
of respondents stated that the procedure for recognition of their EU qualification in another Member State 
could not be completed fully via electronic means (n=283). Several respondents raise examples of such 
difficulties within healthcare and medical professions, despite the shortages currently experienced within 
these professions.  

Professionals that have tried to apply for recognition in more than one Member State also note that there 
are big differences among Member States with regard to how lengthy or complicated the procedure is and 
the costs linked to the procedure. 

Some applicants highlighted inconsistencies in application processes across Member States and mention 
that application processes should be closely harmonised at EU-level to eliminate disparities. Indeed, the 
EU legal framework only sets out minimum procedural requirements and so does not fully harmonize those 
processes, leaving certain flexibility to Member States on transposition and implementation of the rules. 
Respondents  emphasised  the  importance  of  improving  digital  infrastructure  by  adopting  a  centralised 
electronic platform for submissions and tracking of the application process, as reliance on paper processes 
leads  to  inefficiencies  and  delays.  Surveys  also  highlight  a  call  for  transparency  and  for  increased 
communication  from  authorities,  clear  guidelines  and  all-encompassing  resources,  helping  applicants 
navigate the process more effectively. Finally, respondents also mention that reducing the financial and 
procedural barriers by lowering fees and simplifying application steps would make the application process 
more accessible and equitable. 

Many applicants report that they were required to undergo additional tests and training as part of the 
application process. From the applicants’ responses it can be concluded that these requirements primarily 
focus on language proficiency.67 Applicants reported a number of cases when they needed to pass rigorous 
language  assessments,  for  example  proficiency  tests  in  medical  language  at  a  C1  level:  while  some 
countries  accept  B2-level  certificates,  others  require  C1-level  proficiency,  and  in  certain  sectors  (e.g. 
healthcare), applicants must undergo specialised language exams or interviews with professional bodies. 
Some respondents noted that language training was mandatory, even when their professional activities 

67 Language controls are a common prerequisite, especially in host countries where the official language differs from that of 
the applicant's home country. According to Article 53 of the Directive, language controls may be imposed only if the profession 
to be practised has patient safety implications and in respect of other professions in cases where there is a serious and concrete 
doubt  about  the  sufficiency  of  the  professional’s  language  knowledge  in  respect  of  the  professional  activities  that  that 
professional intends to pursue. CJEU case law, however, limits Member States’ liberty in imposing language tests, emphasising 
that such requirements must be proportionate, non-discriminatory, and justified by the nature of the professional tasks. The 
Court has ruled that systematic or standardised language testing, or requiring a diploma from a specific institution, constitutes 
a  disproportionate  burden  and  may  amount  to  indirect  discrimination  based  on  nationality.  Judgement  of  6  June  2000, 
Angonese, C-281/98, ECLI:EU:C:2000:296; Judgement of 5 February 2015, Commission v BE, C-317/14, ECLI:EU:C:2015:63 and 
judgement of 5 July 2000, Haim, C-424/97, ECLI:EU:C:2000:357. 

59 

 
 
 
did not involve direct patient interaction, raising questions about the necessity and proportionality of such 
measures.  

In addition to language tests, several applicants reported being subject to other types of tests and checks, 
including: professional competency exams, such as exams to practice a medical specialty; medical fitness 
checks,  examinations  and  tests;  internships  or  supervised  practice  periods;  written  or  oral  evaluations 
conducted by professional bodies or chambers, sometimes without clear success criteria.  

Overall, the survey responses on additional checks and tests may point to a need for greater clarity and 
transparency in how application procedures are applied to ensure that measures are consistent with the 
Directive.   

10.2 The business perspective  
Based on feedback from associations representing business interests68, companies face several challenges 
when  hiring  professionals  with  recognised  professional  qualifications,  especially  challenges  that  are 
bureaucratic in nature. One of the most significant challenges is experienced due to complex and lengthy 
procedures in some Member States, which can delay the entry of professionals into the market. One of the 
reasons leading to long procedures seems to be the large number of documents that is required and the 
fact that digital solutions are often not in place to process documents and applications.  

In addition, there are language and cultural barriers that can further hinder the integration of professionals 
into the labour market. High international competition for qualified talent and additional costs associated 
with recruiting workers from other countries are also mentioned as barriers, which is especially significant 
in the field of nursing, healthcare and medical professions (i.e. some of the fields with the highest number 
of applications for recognition).  

National business federations also flag that companies sometimes lack information on the content and 
validity  of  qualifications  from  other  countries  and  that  companies  find  it  difficult  to  assess  whether 
qualifications obtained in one country meet the requirements of another country. Differences in education, 
training and qualification requirements across Member States can complicate the recognition process. In 
such cases, businesses suggest that complementarities could be sought to ease the recognition process 
(e.g. through the development of common training principles).  

Businesses also mention challenges experienced by professionals during the recognition procedure. They 
mention  lengthy,  costly,  complex  and  burdensome  administrative  procedures  with  a  lack  of  clear  and 
comprehensible information and support and many professionals being unaware of how to navigate the 
procedure. This also applies to professionals aiming for temporary or project-based work. These hurdles 
are further complicated by language barriers, e.g. in terms of filling out documents in the language of the 
host  country  or  translation  of  documents,  requirements  to  prove  sector-specific  work  experience,  or 
identification of the correct competent authorities for the issuance of attestations of competence.  

Additionally,  businesses  note  that  minimum  training  requirements  for  sectoral  professions  should  be 
updated regularly, and that the quality and content of training provided by establishments awarding a 
diploma for sectoral professions should be better monitored.  

68 Based on input from BusinessEurope and SMEUnited. 

60 

 
 
 
One of the main suggestions for measures that could remove barriers and facilitate recognition procedures 
is to introduce digital solutions, which could reduce the delays and complexity currently experienced by 
professionals.  In  general,  it  is  suggested  that  administrative  procedures  are  simplified,  that  access  to 
information  is  improved  and  that  linguistic  barriers  and  red  tape  are  reduced.  Both  companies  and 
professionals should be supported in the process of recruitment and recognition of qualifications. At EU-
level, fast-track recognition procedures and common training principles (common training frameworks or 
common training tests) could be established for key professions (i.e. professions in which labour and skills 
shortages are the most prominent). Further, it is suggested that measures are introduced at EU-level to 
promote mechanisms for attracting talent, to promote mutual recognition of work experience, to improve 
the flexibility for hiring third country nationals, and to enable  sectoral mobility schemes within the EU 
(similar to Erasmus+ for student mobility). As to the general system of recognition, stakeholders point to 
the need to reduce differences in the implementation of compensation measures.  

At national level, it is suggested that education programmes are aligned with industry needs and that 
lifelong learning as well as training for the unemployed is improved. Information and transparency with 
regard to qualifications should be improved and procedures at national level should be simplified.  

Concluding remarks: Is Directive 2005/36/EC fit for purpose?  
The Single Market provides a unique framework for the free movement of professionals with their skills 
and  qualifications.  The  high  mobility  of  professionals  emphasizes  the  critical  role  of  the  Professional 
Qualifications Directive in facilitating free movement of services, workforce fluidity and addressing labour 
market demands and the demand for professional services. As emphasized by the Single Market strategy 
adopted in May 202569, continuous improvement, effective implementation of the rules on recognition of 
professional qualifications, use of enforcement measures and modernisation of recognition processes are 
vital to sustaining and enhancing the benefits of professional mobility within the EU. 

Overall,  Directive  2005/36/EC  remains  the  cornerstone  of  the  EU  framework  for  the  recognition  of 
professional qualifications and the facilitation of free movement of professionals. It has provided a clear 
legal basis for mobility, especially in highly regulated and mobile sectors such as healthcare, engineering, 
architecture, and education. By establishing common rules on recognition of professional qualifications, 
the Directive has reduced uncertainty for professionals seeking to establish or provide services in another 
Member  State  and  offered  host  authorities  a  structured  process  for  recognition,  as  has  been  widely 
acknowledged by stakeholders. 

The Commission will remain committed to ensure and monitor a clear and sound legal framework for the 
recognition of professional qualifications across the EU for the benefit of the professionals but also for the 
benefit  of  the  citizens  as  consumers  so  that  they  can  receive  a  service  from  a  qualified  professional. 
Enforcement actions will focus on the monitoring of the correct application of the Directive in case of 
establishment and temporary provision of services through dialogue with the Member States, guidelines 
provided to facilitate a coherent application of the Directive and, if necessary, infringement proceedings.  

69 COM(2025) 500 final, The Single Market: our European home market in an uncertain world-  A Strategy for making the Single 
Market simple, seamless and strong 

61 

 
 
 
At the same time, challenges remain to improve and facilitate the recognition of professional qualifications 
across the EU.  

•  Despite simplification measures introduced by the 2013 amendments, recognition procedures 
under  the  Directive  are  still  reported  to  be  lengthy,  unevenly  applied,  and  administratively 
burdensome in certain Member States. Improvements in digitalisation of procedures, speeding up 
and facilitating recognition processes are required to maintain the relevance of the Directive. 

• 

Implementation of the Directive has shown that the empowerments included in it with delegated 
acts have been effective in updating minimum training requirements and lists of professional titles 
without  requiring  a  full  legislative  revision.  This  mechanism  has  provided  flexibility  and 
responsiveness, especially in professions where education and training standards evolve regularly. 
Expanding Commission delegated powers without the need to adopt legislative acts could allow 
for  swifter  updates.  Nevertheless,  such  expansion  would  need  to  be  balanced  with  legislative 
oversight and stakeholder engagement to preserve legitimacy and acceptance. 

•  However,  the  new  mechanisms  introduced  by  the  2013  amendment  have  remained 
underused.  The  European  Professional  Card,  while  successful  in  specific  professions,  has  seen 
limited uptake overall due to administrative complexity, uneven implementation, and insufficient 
awareness among professionals. Similarly, the Common Training Principles have been difficult to 
implement in practice.  

•  At the same time, the reporting and notification system has provided a structured channel for 
transparency  and  oversight.  Member  States  have  been  notifying  the  Commission  of  new  or 
amended  national  rules  affecting  regulated  professions  and  providing  periodic  reports  on  the 
functioning  of recognition  systems  including  statistics  on  the  recognition  decisions  taken.  This 
mechanism has helped to monitor the evolution of national regulation and has created a more 
coherent picture of professional access requirements across the Union. In practice, sometimes, the 
system has faced challenges. Many Member States lack efficient and reliable internal systems of 
recording and collection of data on the length of national recognition processes and recognition 
decisions  taken.  They  often  struggle  with  the  administrative  burden  of  preparing  detailed 
notifications,  particularly  when  changes  to  national  legislation  affect  multiple  professions 
simultaneously. There have also been delays in submitting reports, and variations in the quality 
and completeness of information provided. While the obligations are manageable in principle, they 
remain resource-intensive for some administrations, especially smaller ones. At the same time, 
this data is indispensable to facilitate the mobility of professionals and is also necessary to allow 
for monitoring of the mobility of professionals across the EU. 

•  The  alert  mechanism  allows  Member  States  to  identify  professionals  who  are  prohibited  or 
restricted from pursuing their professional activities in their home State. It was introduced by the 
2013 amendment as an additional source of information (complementing the existing measures 
in the Directive) that can be used to verify the evidence provided by the migrating professionals 
or to monitor the absence of prohibitions or restrictions for professionals established in a Member 

62 

 
 
 
 
 
 
State. However, it is often perceived by public as the only line of defence against professionals 
who are unfit to practice.  The Commission continuously works on making the IMI alert module 
more robust and user-friendly to ensure that all relevant competent authorities use it promptly 
and effectively.  

•  Directive 2005/36/EC, particularly after its 2013 amendment, introduced digitalisation by allowing 
for instruments such as the European Professional Card and use of the Internal Market Information 
system.  These  provisions  demonstrated  the  Directive’s  capacity  to  integrate  digital  tools  into 
recognition processes. The use of electronic procedures and cooperation platforms has reduced 
administrative complexity and signalled the directive’s adaptability to technological developments. 
The Directive’s provisions have proved flexible enough to allow incremental integration of digital 
tools, but lack the clarity and ambition needed to fully exploit the potential of digitalisation. A 
future  revision  could  strengthen  adaptability  by  for  example  explicitly  recognising  digital 
credentials,  enabling  interoperability  across  IT  systems,  and  creating  a  framework  for  the 
digitalisation of recognition processes as technology evolves. This would reduce administrative 
burdens,  increase  consistency,  and  make  the  recognition  system  more  resilient  to  future 
developments.  

63