EUROPEAN COMMISSION

Strasbourg, 15.9.2026

SWD(2026) 993 final

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT REPORT

Accompanying the document

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

on portability of qualifications and skills and amending Regulation (EU) 2018/1724 ("Skills Portabilty Act")

{COM(2026) 992 final} - {SEC(2026) 992 final} - {SWD(2026) 992 final} - {SWD(2026) 994 final}

Table of contents

1.Introduction: Political and legal context

1.1.Overall context of the Skills Portability Initiative and the Fair Labour Mobility package

1.2.Coherence of the package

2.Problem definition

2.1.Background

2.2.What is the problem?

2.3.What are the problem drivers?

2.4.How likely is the problem to persist?

3.Why should the EU act?

3.1.Legal basis

3.2.Subsidiarity: Necessity of EU action

3.3.Subsidiarity: Added value of EU action

4.Objectives: What is to be achieved?

4.1.General objective

4.2.Specific Objectives

5.What are the available Policy Options?

5.1.What is the baseline from which options are assessed?

5.2.Description of the Policy Options

5.3.Options discarded at an early stage

5.4.Intervention logic

6.What are the impacts of the Policy Options?

6.1.Economic impacts

6.2.Social impacts

6.3.Environmental impacts

7.How do the options compare?

7.1.Effectiveness

7.2.Efficiency

7.3.Coherence

7.4.Overall comparison of Policy Options

8.Preferred Option

8.1.Summary of cost and benefits for the preferred Policy Option

8.2.Application of the ‘one in, one out’ approach

9.How will actual impacts be monitored and evaluated?

Annex 1: Procedural information

1.Lead DG, Decide Planning/CWP references

2.Organisation and timing

3.Consultation of the Regulatory Scrutiny Board

4.Evidence, sources and quality

Annex 2: Stakeholder consultation (Synopsis report)

1.Consultation strategy

2.Results of the consultation strategy

3.Summary overview of results

Annex 3: Who is affected and how?

1.Practical implications of the initiative

2.Summary of costs and benefits

3.Relevant Sustainable Development Goals

Annex 4: Analytical methods

1.For the calculations of all the costs and the calculations cost-savings for employers: The SPI Marginal Cost Model

2.For the calculations of cost-savings for workers and issuers of qualifications

Annex 5: Competitiveness check

1.Overview of impacts on competitiveness

2.Synthetic assessment

3.Competitive position of the most affected sectors

Annex 6: SME check

1.Overview of impacts on SMEs

Annex 7: Explanation of main EU tools supporting Skills Portability

1.Policies and tools for improving transparency and portability of qualifications and skills

2.Policies and tools for assessment and recognition of qualifications and skills for the purpose of employment

3.Instruments and legislation facilitating interoperable digitalisation of qualifications

Annex 8: Mapping of information per Member State

1.Purpose of this Annex

2.TABLE 1 - Non-regulated professions

3.TABLE 2 - Digital credentials

4.TABLE 3 - EQF/NQF architecture

5.Member-State Readiness for Digital Qualification Issuance

6.TABLE 5 - Provisions in collective agreements in MS related to qualifications

7.MS Education Providers - VET institutions and HE institutions

8.MS: Annual Issuance Attestation Volume

Annex 9: Policy Options discarded at an early stage

Annex 10: draft monitoring framework

Table 1: Proposed output and result indicators

Table 2: Proposed impact indicators

Annex 11: Visuals for digital implementation and overview of the content of a digital qualification under SPI

1.Overview of an example of an education and training provider issuing a digital qualification

2.Overview of an example of an EU jobseeker using their qualification to apply for a job in another EU Member State

3.Overview of an example of an employer requesting and verifying a digital qualification from another Member State

4.Data elements for a digital qualification awarded after SPI (all POs) and in the past 10 years (PO2)

5.Data elements for a digital qualification awarded before SPI (all POs)

Annex 12: List of tables, figures and diagrams in the main text of the Impact Assessment

Annex 13: Combined impacts of SPI Preferred Options under Action 1, 2, and 3

Annex 14: Descriptors defining levels in the European Qualifications Framework (EQF) – Annex II of the Council Recommendation on the EQF

Glossary

List of abbreviations

1.Introduction: Political and legal context

1.1.Overall context of the Skills Portability Initiative and the Fair Labour Mobility package

While the EU’s labour market has reached record-high employment levels and shown remarkable resilience in the post-pandemic era, 1 its strong performance masks a structural challenge: widespread skilled labour shortages that threaten business growth and the EU’s global competitiveness. 2  

Critical sectors – ranging from healthcare and ICT to construction and transport – struggle to find the talent they need to scale up and drive the twin transitions. These shortages are structural, not cyclical, and expected to worsen due to demographics and evolving demand for new skills and occupations. 3 They are not evenly distributed across the economy and most acutely felt by Small and Medium-sized Enterprise (SMEs), which have fewer resources to navigate complex recruitment channels. 4 Labour and skills gaps also threaten the delivery of essential public services like healthcare, education and long-term care. 5  

Paradoxically, the EU also suffers from ‘skills waste’. Overqualification and the underutilisation of skills remain structural features of the labour market. This mismatch is significantly more pronounced among EU mobile workers and third-country nationals (TCN). 6  

Uncertainty about whether qualifications and skills will be fully understood, valued, and formally recognised (in the case of regulated professions) 7  in another MS, may discourage professionals from seeking employment opportunities outside their MS. 8 It can also deter companies, especially SMEs, from tapping into the potential pool of talent of the Single Market.

Beyond economic efficiency, skills portability is a prerequisite for exercising the fundamental rights enshrined in the Treaties, including the right to free movement (Article 21 TFEU), the freedom of movement for workers (Article 45) and the freedom of establishment (Article 49 TFEU). While individual decisions on relocating to another EU MS depend on many factors, limited skills portability contributes to difficulties that many citizens experience when exercising these rights. In border regions, skills-related barriers to mobility limit job opportunities in neighbouring countries which could be accessed without the need for relocation. 9 Improving skills portability across borders thus also contributes to the ‘right to stay’.

The Letta report on the Single Market to the European Council highlighted that: “Free movement of people has been and remains the least developed of the four freedoms”. It also stressed that fragmented national labour markets hinder European growth and competitiveness and that “extending the system of automatic recognition of professional qualifications and reviewing the need for and extent of professional regulation would facilitate mobility and help to respond to persistent labour shortages”.  10  

In response, the Political Guidelines of Commission President von der Leyen, committed to a “Skills Portability Initiative to ensure a skill acquired in one country is recognised in another”. 11 They also underscored the need to “support MS and companies with legal migration based on the skills needs of our economies and our regions” and to “make it easier to attract the right talent with harmonised rules on the recognition of qualifications”.

At its meeting on 19 March 2026, the European Council urged swifter action, calling for measures to “enhance free movement of workers by improving mutual recognition of professional qualifications and strengthening the portability of qualifications and skills across national borders, including through digitalisation and interoperability, on the basis of a Commission proposal to be presented by autumn 2026”. 12 On 24 April 2026, the European institutions agreed on a roadmap to achieve 'One Europe, One Market' to strengthen Europe’s competitiveness, with a commitment for concrete actions and targets for agreements by end of 2027. The Skills Portability Initiative is one of the priority deliverables to contribute to a more integrated Single Market. 13

This political direction is supported by the broader institutional landscape. The European Economic and Social Committee has called for further discussions among governments, social partners, and stakeholders to consider expanding the list of automatically recognised regulated professions and creating common training frameworks under Directive 2005/35/EC, addressing barriers to its implementation. 14 The Committee of the Regions has highlighted the importance of enhancing the portability and recognition of qualifications across the EU, which are essential for fostering labour mobility, combating brain drain and fully harnessing the Single Market and talent within regional economies. 15  

As part of the Fair Labour Mobility package, 16  the Skills Portability Initiative aims to empower European businesses to recruit the skilled labour force they need to remain competitive in the global economy, effectively safeguard the right to free movement and allow talent to flow seamlessly to where it adds most value. By simplifying and improving the transparency of recognition, and validation, the initiative strengthens coherence between migration pathways, labour market needs and skills systems; supporting improved labour market matching, enhanced productivity and reduced skills underutilisation across the EU.

The initiative aligns with the 2030 Agenda for Sustainable Development, in particular SDG 8 (Decent work and economic growth), SDG 9 (Industry, innovation and infrastructure), SDG 10 (Reduced inequalities) and SDG 1 (No poverty).

1.2.Coherence of the package 

Underemployment, overqualification and ‘skills waste’ stem inter alia from imperfect information and regulatory or administrative barriers to free movement. Mobile professionals struggle to valorise the qualifications and skills they acquired abroad because labour market actors find it relatively more difficult to interpret and verify non-national credentials. This puts qualifications and skills acquired in a non-national context at a disadvantage. The Skills Portability Initiative aims to address these barriers through a set of three distinct but interrelated actions:

Action 1: Improving availability of reliable, comparable and verifiable digitalised information on qualifications and skills in the EU

This action aims to bring simplification for employers and workers by making qualifications instantly understandable and verifiable for labour market actors across the Single Market and facilitating comparison of the level and content of qualifications issued in the EU. It aims to do so by building on existing tools such as the European Qualifications Framework, Europass and the European Digital Identity Wallet, and through setting common standards for digital attestations of qualifications to be interoperable, secure, and machine-readable. This will reduce the ‘interpretative burden’ on hiring managers and preventing further fragmentation between MS resulting from uncoordinated investments in digitalisation.

This action is relevant for all workers using qualifications obtained in other EU MS in any labour market context, including for access to regulated professions. In the context of unregulated professions, which constitute 78% of EU labour force, the improved availability of digitalised and comparable information on qualifications and skills will contribute to decreasing the uncertainty about how to treat qualifications obtained in another MS, which at the moment leads employers to request costly and time-consuming comparisons with national qualifications even though these are not legally required. In regulated professions, the digital attestations set up thanks to Action 1 are a key element of the simplification of the recognition procedures under Action 2. The various problem drivers, Policy Options and impacts are discussed in this IA.

Action 2: Targeted Intervention for Regulated Professions

The second action focuses specifically on improving cross-border recognition procedures for access to regulated professions. 17 There are currently over 5,700 professions regulated across the EU 18 covering an estimated 22% of the labour force, 19 with considerable variations in how these professions are governed and diverging access requirements between MS. This exacerbates the issue of allocative inefficiency as imperfect information is compounded by legal and administrative hurdles to skills mobility. Under the TFEU, regulation of access to professions is MS competence within the limits of EU law, and in particular, non-discrimination and proportionality. 20 Consequently, there is a high variety of approaches to regulating the access to professions between MS which creates barriers to professional mobility within the EU. To address those barriers, the EU has established the Professional Qualifications Directive 21 (PQD) which provides a robust, legally binding framework that sets out rules on the recognition of professional qualifications in a cross-border context. Thus, the Directive facilitates professional mobility, ensuring that individuals who have acquired their professional qualifications in one MS for access to a given profession, can access and pursue the same profession in another MS under the same conditions as nationals. However, the experience of professionals navigating the existing regulatory framework reveals that recognition often remains a complex and time-consuming process. While the framework’s foundations are fundamentally sound, lengthy procedures, uneven digitalisation of national processes and procedures, and heavy documentation requirements risk undermining its potential. Action 2 aims to facilitate cross-border recognition of professional qualifications required to access regulated professions is organised into two primary work strands. The first work strand focuses on applying the automatic recognition system to additional regulated professions. Currently, automatic recognition exists for certain sectoral professions with harmonised minimum training requirements (such as doctors and nurses). For specific economic activities in trade and commerce there is automatic recognition based on professional experience. The action aims to extend automatic recognition to professions which are not currently covered using Common Training Frameworks. It is covered as part of the baseline in the dedicated IA for action 2. 22 The second work strand on Modernisation and Digitalisation of Procedures aims to simplify and speed up recognition of professional qualifications for regulated professions, by streamlining the existing recognition procedures under the Directive, leveraging the potential of digital tools. Action 2 is based on articles 46, 49, 53 and 62 TFEU. The various problem drivers and Policy Options in this second work strand are discussed in a dedicated IA.

Action 3: Attracting and Empowering Global Talent

Acknowledging that intra-EU mobility alone cannot solve all labour market needs, Action 3 focuses on making the Single Market a more attractive destination for TCN by enabling them to have their qualifications recognised and their skills validated more easily. This will both benefit the TCN already residing and working in the EU and those who intend to migrate to the EU, making the Single Market a more attractive destination for global talent. Action 3 is based on article 79 (2) points (a) and (b) TFEU. The various problem drivers and Policy Options in this third work strand are discussed in a dedicated IA.

Actions 1, 2 and 3 are closely interlinked and coherent.

The interoperable, secure and verifiable digital attestations developed under Action 1 are a foundation, on which actions to simplify and speed up recognition procedures in the context of regulated professions under the PQD (Action 2) build, by reducing administrative burdens on Competent Authorities enabling smoother, faster assessments of qualifications.

Action 3 addresses a critical gap: the PQD’s recognition procedures do not cover third-country nationals (TCNs). TCNs and EU citizens holding non-EU qualifications do not always benefit to the same extent from the existing EU transparency tools. This puts them at a disadvantage compared to EU citizens holding EU qualifications, undermining the attractiveness of the Single Market as a destination for global talent. To address these issues, specific action to facilitate recognition of qualifications of TCN is warranted. This is the purpose of Action 3. Just like Action 1, Action 3 uses the European Qualifications Framework as a key tool to enable comparability and portability of qualifications across borders, implemented in particular through comparisons between the EQF and qualifications frameworks of third countries, such as in the context of Talent Partnerships, or other EU partnerships.

Together the three actions form a coherent package, each addressing distinct but interlinked dimensions of skills portability: 1) the framework for availability of digitalised information about qualifications and skills which forms the foundation for the other actions, 2) the recognition of qualifications for intra-EU mobility in regulated professions, and 3) the recognition of qualifications of TCN. As such, the three actions are mutually reinforcing and contribute to the broader objectives of supporting labour mobility, reducing skills mismatches, and improving the functioning of the Single Market.

This IA focuses on Action 1 of the Skills Portability Initiative: “Improving availability of reliable, comparable and verifiable digitalised information on qualifications and skills in the EU”.

2.Problem definition

2.1.Background

Qualifications and their signalling role on the labour market

Employability, broadly defined as the capability of an individual to secure and sustain employment, is determined by a wide range of factors relating both to personal attributes and the prevailing economic context. There is clear statistical evidence that that among the personal attributes, the level of educational attainment, i.e. the successful completion of an education programme being validated by a recognised qualification influences employability (see Eurostat LFS). 23

This does not mean that qualifications are the only element that employers consider when recruiting people, and many internal and external factors can influence their choice. It nevertheless ultimately means that a significant number of them 24  take into account, at least to a certain extent, the qualification of their potential future workers in their hiring decisions.

The role of qualifications in reducing the uncertainty of firms as regards the future productivity 25 of the recruited labour force has been long established in the literature. For Arrow, higher education serves as a screening mechanism of the differing abilities of individuals and in this respect conveys information to the purchasers of labour in a context of imperfect information on workers potential job performance. 26 Spence presents the level of education as a signal on the job market for employers who cannot directly observe productivity ex ante recruitment. Spence also underlines the existence of a feed-back loop: the conditional probability of productivity level attached to one signal (a qualification) is adjusted after each round of hiring which allow observing the productivity level of recruited workers holding this qualification. 27 Stiglitz further elaborates on the features of education that make information a natural by-product of its activity of providing skills (including through the self-selection of individuals who, if they are rational, will try and acquire qualification depending on their ability) and explains how education reveals individual productivity in markets with imperfect information. 28

In view of the above, companies consider qualifications when selecting future employees. The exact individual decision-making process cannot be observed, nor aggregated but one can postulate that companies who require qualifications when advertising a vacancy and/or in the application file will take them into consideration. An ad-hoc query on the Skills Online Vacancy Analysis Tool for Europe yield that 23% of online vacancies include a least one wording directly related to qualifications. 29 This figure is in the same order that the percentage (29%) of SME panel’ respondents indicating that they require a qualification when hiring. Empirical works at national level also point toward the fact that qualifications are requested in job applications. For instance, an analysis of the French Ministry of labour 30 found that 38% of the surveyed employers were requesting candidates to include their diplomas and training certificates in their file. A study from Poland shows that in 42% vacancies employers ask for suitable education. 31

The weakened signal of foreign qualifications

The Eurobarometer on the Thirtieth anniversary of the EU Single Market 32 reports that a recurrent theme across multiple focus groups involved the difficulties individuals faced when their degrees and qualifications acquired in one EU country were not promptly acknowledged or recognised in another. Some participants spoke about challenges linked to the recognition of qualifications as an issue that they faced themselves or knew other people who did.

It is not possible to quantify the weight of the different factors that may hamper EU labour mobility as they relate to individual decisions of workers and/or employers. Some insights can nevertheless be drawn from a survey of the Austrian Chamber of Commerce among their members in 2024. 59.0% view the assessment of professional qualifications as a very or somewhat significant barrier; while 54.4% point to the high rent and housing costs in the region. 47.5% view the evaluation of foreign educational credentials, and 40.0% view the search for and recruitment of non-Austrian skilled workers as a very or somewhat significant problem. The need to make foreign educational credentials more understandable and comparable in terms of the content they cover is raised by nearly half (47%) of the Austrian companies surveyed; 18% do not see this need, and 35% declined to give a specific answer (“don’t know”). This example from one Member State gives an indication that employers may have difficulties understanding qualifications acquired in another one. Answers from the SME Panel Consultation point in the same direction: when asked about the specific challenges they face in assessing qualifications from other EU countries, the most frequently cited challenge was insufficient familiarity with foreign education systems. 33

The signalling role of qualification has also been used in the literature addressing the transferability of immigrants’ human capital on the American, the Swedish 34 or German 35 labour markets. In these cases, the authors argue, based on empirical analysis, that foreign education has lower returns because employers refrain from hiring workers with foreign educational credentials that they do not fully understand. Lancee and Bol 36 also attribute the wage penalty observed for non-Western degrees after controlling for different forms of skills to the fact that employers are less likely to be familiar with them.

One can also argue that foreign qualifications as a signal benefit less from the feedback loop described by Spence (1973). The feedback loop occurs when a firm observes the productivity of a hired worker with a qualification and is then able to improve the information conveyed by the said qualification. Qualifications acquired in foreign countries are likely to benefit less from this feedback loop then the domestic qualifications as firms are still likely to recruit fewer workers in a firm holding a qualification from a foreign country.    

Policy initiatives and existing EU tools relevant for the comparison of qualifications across the EU 37

The need to improve the understanding of qualifications and skills obtained in different MS has long been acknowledged, and the EU has invested in a number of policies and tools in that context.

The European Qualifications Framework (EQF) aims to increase the transparency and comparability of qualifications. It connects the national and European qualification levels. The national qualifications are part of national qualifications frameworks (NQFs) and NQF is referenced to the EQF. The EQF consists of 8 levels from basic (level 1) to advanced (level 8), based on learning outcomes (knowledge, skills, autonomy and responsibility). 38  

The Europass platform 39 operates as a one-stop shop for different skills, qualifications and labour mobility tools, including an e-portfolio with a smart CV, information on qualifications (from NQF registers) and learning opportunities (from national registers/databases) and an infrastructure for digital credentials (the European Digital Credentials for Learning).

ESCO (European Skills, Competences, Qualifications and Occupations) is the EU's multilingual classification of skills, competences, qualifications and occupations, designed to improve transparency and matching across EU labour markets. It enables employers and employment services to describe vacancies and worker profiles in a common language that crosses national boundaries.

The use of these tools is voluntary which limits their potential to fully address the lack of understanding of a qualification acquired in another Member State (for a full description of these limitations, see Section 2, sub-Driver 2.1). Annex 7 provides a full overview of these tools, as well as of the various actors involved in recognition and assessment of qualifications obtained in other MS (e.g. ENIC/NARICs) and more recent developments related to digitalisation which have impacts on portability of qualifications (e.g. EUDI Wallet and DC4EU pilot).

2.2.What is the problem?

The portability of qualification and skills is limited across the EU and makes it more difficult for employers to hire, and EU mobile and cross-border workers to get hired.

Employers and other labour market actors that need to read, understand, and verify qualifications obtained in another MS (e.g. public employment services matching jobseekers to jobs, recognition authorities in case of regulated professions), face two interconnected problems of information asymmetry. The first one related to uncertainty about what a qualification contains (e.g. the learning outcomes). The second one stems from the technical ‘envelope’ (for example paper vs digital format) as well as its level of security (for example, seal on paper or encrypted digital credential) that may lead to adverse selection (e.g. risk of fraud).

Employers navigate a hiring process, where they may lack understanding of the language the diploma is issued in and the type of information the qualification contains may be very different from the national context. As shown in the consultation, labour market actors do not understand qualifications from other MS well enough to assess what the holder truly knows or is able to do – i.e. the qualification level and content. 40 Confidence of SMEs falls significantly when assessing qualifications from other EU countries, compared to from their own country. In the SME Survey, 41 for qualifications from other EU countries, 31 (out of 159) report feeling very confident, 86 (out of 159) are confident, compared to 84 (out of 159) feeling very confident and an additional 59 (out of 159) feeling confident in assessing qualifications from their own country. The most frequently cited challenge when assessing qualifications from other EU countries by SMEs, was insufficient familiarity with foreign education systems (70 out of 159), difficulty verifying the authenticity of qualifications (63 out of 159) and language barriers (61 out of 159).

The Europass evaluation 42 pointed out that verifying the authenticity of a candidate’s qualifications is very important for employers when hiring (71% of respondents consider it very important or somewhat important). At the same time, 59% of the employers consider the process of verifying the authenticity of candidates’ qualifications or experience to be often or sometimes difficult and slightly more than half of them (54%) consider receiving digitally certified documents proving qualifications to be important.

As reported by stakeholders consulted in the supporting study, non-digital credentials are subject to an increased risk of fraud. Over half of the respondents (298 out of 574) to the survey of issuers of qualifications (strongly) agreed that paper certificates cause problems with verification checks, and five submissions to the Call for Evidence reported that remote verification is “impossible” with analogue systems. 43   The concerns about the growth of diploma mills and fraudulent qualifications across Europe were raised in the Council of Europe's Recommendation on countering education fraud and the Lisbon Recognition Convention Committee. 44 Empirical analysis by CIMEA 45 similarly documents a thriving landscape of forged and fabricated credentials, distinguishing between "fake degrees" issued by entirely fictitious institutions and "fraudulent degrees" that mimic genuine ones, and notes that new digital tools are making both easier to produce and harder to detect.    

Imperfect information about the level and content of qualifications acquired in another MS and the format in which they are presented may reduce trust, increase transaction costs and make acceptance and recruitment decisions more difficult. Further, they may lead to unnecessary and burdensome procedures and to suboptimal outcomes for both workers and employers.

The problem tree (diagram 1) illustrates the problem, main drivers, their causes and consequences.   

Diagram 1: Problem tree

The problem identified above has distinct implications for different stakeholders.

Employers

Employers may spend time trying to understand qualifications coming from different education and training systems, have to invest ex-post recruitment in supplementary training when skills cannot be verified, and face significant indirect and opportunity costs.

The determination of the exact number of employers who undertake to verify the qualifications of the applicants acquired in another MS is not possible. No empirical study has been identified on this matter and since this would mean a controlled experiment on a representative sample of EU companies it was not possible to undertake such an analysis for this impact assessment. Having said that using job scraping, 46 from the CEDEFOP Skills Online Vacancy Analysis Tool for Europe yield the result of about one quarter of the job advertisements containing a reference to qualification(s). One can assume that EU employers mentioning qualification when publishing a vacancy will take this into consideration and verify the qualification at least of the selected applicant. Estimating the number of verified qualifications to about one quarter of the flow of mobile workers per year seems a reasonable (low range) assumption. This estimate could even be considered as conservative as it takes as a basis only the flow of mobile workers (hence mobile workers who apply to change jobs in the MS they already reside are not counted) and does not include cross-border workers.

In addition, reduced access to talent, in a context where many of them are already not finding candidates with the right skillset, worsens existing labour and skills imbalances. In the Eurobarometer 2023, skills shortages were reported as the most serious problem by 53% of micro companies, 65% of small companies, 68% of medium-sized companies, and 72% of large companies. 47 In the 2025, out of 423 occupations identified as being in shortage in at least one country, 416 (or 98%) also appear as surplus occupations in at least one other country. Even in case of one of the occupations most frequently reported as being in shortage – welders and flame cutters (flagged by 22 countries), two countries reported a surplus. 48

Potential EU mobile workers

The most affected are individuals seeking to access or exercise a regulated profession in another MS for whom the recognition of their qualifications is compulsory. Many MS still require physical submission of documents as fully digital procedures are not always available. For applicants, this reliance on physical documentation increases costs, administrative burden, and delays. 49

Individuals wishing to move and work in a non-regulated profession, may also be requested to undertake a qualification assessment procedure, not for legal reasons but to provide prospective employers with further information on the level, content and the authenticity of their qualifications, which are also costly and entail significant administrative burden. Around one in three of respondents in the SME panel request some kind of qualification assessment procedures to verify the authenticity of the qualifications (52 out of 159), or to better understand what candidates have learnt compared to domestic equivalents (42 out of 159) in non-regulated professions. In response to employers’ request to obtain some formal assessment of qualifications in non-regulated professions, workers use recognition pathways designed for other purposes, such as statements of comparability issued by ENIC-NARIC centres. 50  Most ENIC-NARIC centres were not able to estimate the percentage of statements issued for non-regulated professions. However, in countries where estimates were submitted, they represented more than half of all statements (see Annex 8, Table 1).

In some instances, although not required from hiring purpose, the necessity of the formal assessment may stem from the prevailing collective bargaining agreement - determining the working conditions. For example, in Italy, while contractual grading is determined primarily by the tasks assigned rather than by formal qualifications, a comparability statement or qualifications mapped to the EQF is often used to facilitate recruitment by making workers' qualifications and skills obtained in another EU MS more transparent and understandable to employers. In Poland, the collective agreements also link grading and remuneration to education levels, seniority and qualification requirements for specific positions, but they generally do not address the treatment of qualifications obtained in another MS. 51  

The financial burden of these processes was one of the most cited challenges in the call for evidence, and the cost falls often on the workers themselves. While most respondents reported spending less than EUR 250, cases around EUR 1 000 were also reported. Beyond direct costs, nearly half of the respondents to the consultation reported processes lasting longer than three months, generating significant lost opportunity costs (periods without income).

Such costs can be difficult to bear especially for individuals from vulnerable backgrounds and younger workers. Young people, especially those entering the labour market, are likely to be more affected since qualifications are likely to play a stronger role in their ability to access entry-level jobs which per definition do not require professional experience. In addition, the cost and length of the recognition procedures are likely to weigh more on them than on workers already employed. However, the available data do not allow to estimate the extent of this happening.

Issuers of qualifications

Issuers of qualifications are frequently contacted by third parties, such as employers, recognition authorities or other organisations, to verify the authenticity of qualifications. According to the Qualification Issuers Survey, 290 out of 574 respondents (50.5%) reported having received requests from third parties to verify the authenticity of diplomas. The annual requests per issuer are estimated in range from 16 to 30 contacts per year, with the lower and upper values reflecting different interpretations of the open-ended “once a week or more” category. 52

2.3.What are the problem drivers?

The underlying drivers stem from market failures related to an imperfect information on qualifications and skills. This leads to asymmetries of information on level and content of qualifications (driver 1) and on the authenticity of the qualification (driver 2).

The two drivers are mutually reinforcing. Because of uncertainty on the level or content of a qualification and skills (Driver 1), the same applicant may face additional hurdles about its authenticity when presenting their qualifications to an employer in another Member State (Driver 2). Within each MS, a highly diverse landscape of qualifications exists. The fragmentation of IT systems being developed in an uncoordinated and un-interoperable way is making more complex for employers to verify easily digital qualifications (Driver 2) and access its content (Driver 1).

Driver 1: Labour market actors have insufficient understanding and uncertainty about level and content of the qualifications and skills obtained in another EU MS

The education and training systems, as well as what credentials delivered, are organised differently across 27 MS, since this falls under the responsibility of the EU MS. 53 As a result, when an individual with qualification from another MS applies for a job, the employer will receive qualifications credentials that diverge in language, content, descriptions compared to a job application from a native worker. This is a problem for all, regulated and non-regulated professions. 54  

The qualifications credentials are typically written in the local language(s) and the same time across the EU, qualifications contain various amount and quality of data, e.g. on learning outcomes (see illustrative example).

For an employer, what matters is to compare and understand how the foreign qualification credentials/learning outcomes relate to their national system. The EU and MS have developed transparency tools that aim to ensure reliable information on qualifications from across the EU and allow, to a certain extent, their comparison but their implementation is incomplete.

The transparency tools are the European Qualifications Framework, Europass and ESCO, which are closely interlinked. The backbone of this toolbox is the European Qualifications Framework (EQF) , in place since 2008 (and reviewed in 2017), aiming at enhancing the transparency, comparability and portability of people's qualifications. The EQF is a reference framework consisting of 8 levels of proficiency of learning outcomes (knowledge, skills, autonomy and responsibility) that operates as a translation tool between national systems and supports both lifelong learning and employability. MS are invited to relate their national qualifications frameworks (NQFs) to the EQF, in order to establish a clear and transparent relationship between their national qualification levels and the eight EQF levels, through a process called referencing.

The referencing process uses the EQF referencing criteria as assessment benchmarks. The 10 referencing criteria include the way in which MS use the learning outcomes approach, how qualifications are included in NQFs and how qualifications are quality assured in line with national and international standards. National quality assurance bodies and international experts (at least two) must sign off each referencing report, which needs the endorsement of the EQF Advisory Group through a specific peer review process. Overall, the referencing criteria and the governance of the EQF referencing process provide a solid foundation for trust in NQFs and the EQF as a whole, as also confirmed in the EQF evaluation of 2024. 57  

However, there is diversity and unevenness across the EU in terms of the implementation of the EQF through NQFs. While all NQFs are based on learning outcomes, which is a condition for EQF referencing, they vary in their maturity and the amount and quality of information they provide on qualifications.

Cedefop has provided information on the stage of development of NQFs. 58  Eighteen MS have reached the operational stage: 59  their NQFs provide a map of NQF qualifications and a reference point for development and review of standards and curricula; NQF levels are indicated on certificates and diplomas, qualifications registers/databases are functional, and quality assurance mechanisms are in place. Other nine MS 60 are in the activation phase meaning that the implementation structures and the criteria and procedures for allocation of qualifications to levels have been set, and the main instruments are being put in place (e.g. databases, quality assurance arrangements); awareness of end-users is gradually growing.

Another weakness in the use of the EQF and NQFs is the uneven updating of the original referencing.  The recommendation to update the referencing was included with the revision of the EQF Recommendation in 2017, while mentioning that it should be done with due regard to the national context. However, as the EQF evaluation concluded, particular focus would be needed by MS to ensure referenced reports are up to date. In 10 of the 13 MS that have not updated their referencing yet, the initial referencing report dates back 10 years or more, 61 while 14 MS have updated their referencing report since the EQF revision of 2017. 62 While MS agreed to possible criteria indicating the need to update referencing reports (such as a national legislative and institutional developments in NQFs), implementation depends on voluntary choices by MS as to when review and update their EQF referencing; decisions to update referencing do likely depend on prioritisation and available resources at the national level.

These weaknesses affect the usefulness of the EQF for employers, who at the same time are interested in reinforcing the tools. Eurochambres, an EU-level association of employers exemplified this in their written input: “Companies have an interest in ensuring that qualifications obtained in other MS are transparent and comparable. This is particularly relevant in border regions, where businesses rely on daily or seasonal cross-border mobility of workers. Existing transparency instruments such as the European Qualification Framework (EQF) and National Qualification Frameworks (NQFs) provide an important foundation and should be further strengthened and better connected, including through improved data exchange at EU level”.

The Europass platform intends to operate as a one-stop shop for skills and career management, with different skills, qualifications and labour mobility tools, including an e-portfolio, information on qualifications (from NQF registries) and learning opportunities, an infrastructure for digital credentials (European Digital Credential for Learning infrastructure) and Europass supplements with a common structure and template: Diploma Supplements (higher education), Certificate Supplements (VET), and Europass Mobility (learning mobility). Thanks to their standardised format, the supplements improve the transparency and comparability of qualifications in an international context, supporting skills portability.

The data shared with Europass consists of an EU database on qualifications77 and the data is also republished as open data on the EU open data portal. However, ensuring that databases and registers of qualifications are connected to the Europass platform was still mentioned as an area of attention by the EQF evaluation. So far 14 MS share data on qualifications with the Europass platform,78 while an additional two MS79 are testing the system. The other MS have either not connected their database with Europass,80 or do not have a database at all.81 Among the 14 MS that do share qualifications data, these do mostly not cover the full scope of the NQF (some MS share only VET or higher education qualifications), do not contain permanently updated datasets, and regularly contain poor data quality, in particular on learning outcomes. Differences in implementation can be explained by the voluntary nature 63 of these activities and do likely depend on prioritisation and available resources at the national level. Transparency, recognition and matching tools, have more recently been complemented by instruments facilitating the interoperable digitalisation of information related to qualifications and skills. These include the European Digital Credentials for Learning (EDC)82 as a multilingual format for electronically sealed, digital presentations of learning credentials. The EDC Infrastructure is part of the Europass platform and includes ready-to-use tools for building, issuing and viewing these digital credentials. Issued digital credentials can be stored directly in the My Library section of a person holding a Europass account. EDCs are signed using an electronic seal, ensures credential integrity and which must be acquired from Trusted Service Providers, in line with the EU legal framework for electronic seals, the eIDAS Regulation. EDCs are designed to promote cross-border recognition of credentials. To this aim, they are based on a multilingual European standard for semantic interoperability,83 the European Learning Model (ELM). However, EDC is a voluntary tool for any organisation wishing to issue digital credentials. It was not designed to serve as the single solution for the digital transformation of all credentials across the Union. Moreover, it was developed before the EUDI Wallet and is not linked to the digital identity of credential holders, nor does it provide the same safeguards against fraud. Upgrading EDC to meet such requirements would require substantial investment. Therefore, EDC is not currently suitable for a Union-wide rollout.

Some MS have put in place their own measures to overcome information asymmetry on qualifications and skills obtained in another EU MS (and beyond). Several MS have developed databases of foreign qualifications helping the understanding and recognition of these by employers and other stakeholders. These databases do generally have a broad geographic scope, including EU and non-EU qualifications. 64 MS databases and/or country profiles that include EU qualifications are those of the BE French-speaking Community, France, Germany , Greece, Ireland , Italy, Netherlands , Poland and Sweden 65 . For Ireland, the Netherlands, Poland, and Sweden, - the EQF level of qualifications functions as reference point. In Ireland an open database of foreign qualifications run by the Quality and Qualifications Ireland (QQI) covers over 2,000 qualifications from across the world, mapped to the Irish NQF. The Polish “Qualificator” database allows users to obtain an automated comparability statement with a Polish reference qualification, while the Swedish database provides for comparisons between foreign qualification types (e.g. a bachelor's in science) in relation to Swedish qualification types. According to the German Recognition Act, since 2012 all holders of a foreign professional qualification have a legal right to have their professional qualification assessed for equivalence with a corresponding German reference qualification, including for non-regulated professions. The German BQ Portal supports this right by focusing on comparing curricula (learning activities), but it does not use the EQF levels as reference point. Similarly, the Anabin database facilitates classification of foreign qualifications for regulated professions within the German education system, also without reference to the EQF.

While these different databases fulfil different national needs, they do not use the same terms and definitions, they do not use the same reference points, and there is no coordination between them. Taken together, there is fragmentation, a lack of interoperability and duplication of work, time and resources by MS.

Driver 2: Labour market actors cannot verify (and workers cannot efficiently prove) the authenticity of qualifications and skills credentials issued in another EU MS

As noted in the Europass evaluation, “(…) employers face difficulties when verifying the authenticity of candidates’ qualifications or experience (59% of them consider this process to be sometimes difficult or often difficult). Verifying the authenticity of a candidate’s qualifications is very important for employers when it comes to hiring (71% of respondents consider it very important or somewhat important). Slightly more than half of them (54%) consider receiving digitally certified documents proving qualifications to be important”.

The education and training systems are organised differently across 27 MS. Combined with the diversity of credential systems and related verification methods across MS, it makes it difficult for labour market actors to verify the authenticity of credentials.

This is a problem across all professions, regulated and non-regulated. In fact, for the regulated professions, for which a recognition process is observable, authenticity verification is one of the most resource-intensive elements of the recognition procedure, and a recurring source of both direct and indirect delay. In regulated professions, trust between MS is the foundation on which the recognition system built by Directive 2005/36/EC (PQD) rests. The general system, the automatic recognition regime for sectoral professions and the various forms of administrative cooperation established under the Directive all depend on the assumption that a qualification document presented by an applicant genuinely corresponds to training actually completed and genuinely awarded by the institution named on it. Where that assumption cannot be relied upon, the whole architecture of mutual recognition is put at risk. Competent Authorities (CA) survey evidence collected for the SPI Action 2 impact assessment confirms that the time required for authenticity checks is cited as a distinct source of delay in recognition procedures, and that core assessment activities, including document authenticity checks alongside equivalence assessment and drafting of decisions, frequently require 30 or more man-days annually. This burden is compounded by the continued reliance on paper-based documentation in many MS and professions, since paper documents are not inherently verifiable and require additional authenticity checks that are increasingly complex in light of evolving fraud risks, including AI-based falsification. The consequences extend beyond CA workload: the survey evidence also indicates that a degree of institutional caution, including doubts about the authenticity of documents, contributes to the broader pattern of procedural prudence that CAs apply when assessing qualifications obtained in another Member State, even though this is not formally identified as a problem driver in the impact assessment.

The shift to interoperable, verifiable digital attestations is the single most consequential structural response available to this problem. In case of regulated professions, for example, an automatic authenticity checks at the point of verification thanks to the digital attestations, rather than through a subsequent, resource-intensive process, would remove the need for the manual, document-by-document authenticity checks that currently consume significant CA staff time. This is reflected in the policy options considered for Action 2, which assume as a pre-condition that as a result of Action 1 a legal obligation would be set on MS to issue qualifications as interoperable digital attestations meeting common EU requirements on verifiability, authenticity, trust and interoperability, and a corresponding obligation on host MS to accept such attestations as valid evidence without further authenticity confirmation from the home Member State.

The rollout of digital credentials has been uneven between MS so far. Based on Annex 8.3 table 2 on digital credentials 66 , an initial assessment of MS readiness to issue digital credentials was developed. The variables used were the digital credentials tools that are in use and the infrastructure that is already in place, the digitalisation status (whether digital credentials are actually in use or not) and the digital diploma legislation (whether an enabling legal basis exists or not for their issuance). This led to an identification of three types of MS:

·Type A: Advanced (6 MS): EE, ES, HR, IT, LT, NL. National or multi/regional infrastructure in place and confirmed use.

·Type B: Developing (14 MS): BE, BG, CZ, DK, FI, FR, LU, LV, MT, PL, PT, RO, SE, SI. Some infrastructure present but use limited, partial, or unconfirmed — or partial use without stable national infrastructure.

·Type C: Early development (7 MS): AT, CY, DE, EL, HU, IE, SK. No national infrastructure; where a tool type is coded, reliance is on EU-level tools only with no confirmed national uptake.

This progressive digitalisation of qualification credentials in MS is occurring in an uncoordinated manner. Achieving interoperability requires technical alignment 67 and shared semantics (e.g. common skills taxonomies and qualification descriptions). Many systems rely on national standards or closed networks, which hinder EU-wide scalability. This entails the risk of a fragmented digitalisation across MS that could ultimately make even more difficult for employers to simply read and verify the qualification credential acquired in other MS because they would not have at their disposal the software necessary to understand the digital credentials.

A key development in the context of interoperable digitalisation has been the Regulation on electronic identification, authentication and trust services (eIDAS) of 23 July 2014 (Regulation (EU) No 910/2014). The eIDAS Regulation has created standards for electronic signatures, qualified digital certificates, electronic seals, timestamps, and other proof for authentication mechanisms which enable electronic transactions, with the same legal standing as transactions performed on paper. The eIDAS Regulation was reviewed in 2024. The eIDAS 2.0 includes the European Digital Identity Wallet (EUDI Wallet), which requires that MS have a compliant wallet available by the end of 2026, the use of which by citizens is voluntary. Each version of the wallet will be interoperable and will work across the EU. EUDI Wallets will be able to store and share a wide range of digital documents, including driving licence, 68 social security documents 69 and the digital travel credentials 70 . Qualifications are listed among the individual's attributes that could be included in an EUDI Wallet. To this end however, specific sectoral requirements (e.g. on the trust framework, the attestation content, the governance) need to be laid down in sectoral legislations, as it is the case of the driving licence and will be proposed for social security documents.    

To test the use of the EUDI wallet in relation to the issuance, storage and presentation of verifiable digital credentials through wallet-based solutions for educational qualifications and learning achievements, the Digital Credentials for the European Union (DC4EU) was conducted as a large-scale pilot project. 71 The target system explored by the DC4EU project was an integrated digital ecosystem that addresses potential fraud and credential validation challenges, complies with European educational and professional qualification standards, increases acceptance among all relying parties (employers, educational institutions, professional bodies) and supports the free movement of professionals and students across the EU. The DC4EU framework for educational and professional qualification credentials is based on an architecture that includes the European Learning Model (ELM) as semantic foundation, and the W3C Verifiable Credentials Data Model for technical implementation.

The EUDI Wallet complements the Single Digital Gateway Regulation  (SDGR) (Regulation (EU) 2018/1724) which facilitates the online access to information, administrative procedures, and assistance services that EU citizens and businesses may need in another EU Member State. It includes procedures for the academic recognition of diplomas, certificates or other proof of studies or courses. There is no procedure today in the SDGR to request a diploma for the purpose of applying for a job in another EU MS. To implement the SDGR, the Once-Only Technical System ( OOTS ) was created as the core infrastructure. It aims to save EU citizens and businesses time and money by allowing the automatic exchange of official documents and data (such as diplomas, certifications or permits) between the ‘competent authorities’ that issue this data and the public body requesting the data. The ELM was recently complemented with new data fields to cover the education-related use cases from the OOTS, allowing for the exchange of structured data. 

In addition, paving the way for a potential inclusion of qualification in the EUDI Wallet, a common floor of standardisation is already in place: all MS have referenced their NQFs to the EQF. MS are aware of the European Learning Model (ELM), which provides a shared vocabulary for describing learning outcomes. As indicated earlier, 14 MS share data on qualifications with the Europass platform, 72 while an additional two MS 73 are testing the system and are therefore able to share data in the European Learning Model (ELM) format. 74 As of July 2026, the other MS have either not connected their database with Europass, 75 or do not have a database at all. 76  All MS have been invited to training sessions on the ELM over the years and MS are kept informed and shape the changes in the data model via the EQF AG and the Europass AG. ELM has also been discussed to become a semantic model to be supported in OOTS for exchanging structured data for the studying procedures. While a formal decision has not yet been made for its inclusion, there is a strong awareness of the semantic model across the MS in the SDGR group.

All 27 MS participate in the implementation of Europass and discuss the topic of digital credentials in the Europass AG and are familiar with verifiable digital credentials. 18 countries piloted the Europass digital credentials between 2019 77 and the official launch of EDC in 2021. 78 As the implementation of EDC is voluntary and open, there is no official MS participation in its implementation. No complete data of EDC issuers exist due to the absence of tracking of the issuers and users. Certain MS, such as MT, 79 LU 80 and ES 81 are among the most active EDC users.

On the readiness regarding the implementation of the EUDI Wallet, no MS has yet certified a production wallet compliant with eIDAS 2.0, which can be explained by the fact that the latest specifications detailed in the Commission Implementing Regulation of 15 July 2026 82 are yet to enter into force and the fact that MS have until December 2026 to offer an EUDI Wallet to their population. During the EUDI Wallets launchpad event of December 2025, 83 “the demos revealed different levels of readiness across MS, alongside a powerful opportunity: some countries are ready to lead, while others bring complementary strengths, sectoral expertise, or user reach”. 84 Figure 1 presents the overview of MS maturity and readiness in December 2025.

Figure 1 - MS digital wallet readiness (from the 2025 EUDI Wallet launchpad event key takeaways)

The analysis of MS readiness was further refined when cross-checked with DC4EU data and data from the EMREX network. On education credential infrastructure the ordering is close to inverted: several of the MS operating the most mature national diploma registers, sector agencies and student data exchange arrangements are among those least advanced on the wallet substrate into which those credentials would have to be issued. Different governance exists across the 27 EU MS, which also needs to be accounted for when proposing issuance solutions of qualifications. This analysis led to the clustering of MS into four groups (see point 5 in Annex 8 for additional information):

·Cluster A (4 MS): DE, DK, FR, IT. Wallet-ready front-runners (production or public sandbox)

·Cluster B (4 MS): EE, FI, NL, SE. Education-credential leaders, slower wallet substrate

·Cluster C (9 MS): AT, BE, EL, ES, IE, LU, MT, PL, PT. Engaged fast followers (Tier 2 eID app or strong governance role)

·Cluster D (10 MS): BG, CY, CZ, HR, HU, LT, LV, SI, SK, RO. Building / lagging substrate

Issuance is at the same time organised around two persistent topologies, with the trust chain running either through a national research and education agency acting as an aggregation layer for autonomous institutions, or through a ministry or a central diploma register, and both are expected to coexist. The consequence for the labour market actors of the digitalisation described above is that the ability to verify a qualification depends less on the qualification itself than on where it was awarded and on the sequencing of national digital programmes pursued for unrelated reasons.

In addition, there is the issue of lack of legal clarity regarding the acceptance of digital documents from another MS, leading to a digital trust gap where even when digitally issued credentials are available, they may not always be understandable, verifiable and trusted across MS. The Beyond DC4EU report 85 highlights the risk of fragmentation, writing that “If MS develop divergent interpretations of which credentials must be accepted and under what conditions, cross-border recognition risks becoming contingent on bilateral practices rather than on the uniform application of Union law. In such a scenario, a credential that is routinely accepted in one Member State may be questioned or rejected in another, not because of differences in cryptographic security or issuance quality, but because national authorities have formed different views on acceptance obligations, liability exposure, or supervisory responsibility. Pilot experience indicates that once such interpretations are embedded in operational systems and verifier workflows, they are difficult and costly to reverse”.

Overall, this complex landscape shows that there is a diversity of credentials systems in the EU, complicating authenticity checks, and while digitalisation offers a way to simplify authenticity checks and at the same time improve the availability of standardised and reliable information on qualifications, the take up among the MS is varied, and even with tools such as EUDI Wallet, Europass and the SDG interoperability is not possible to achieve without sectoral legal standardisation.

2.4.How likely is the problem to persist?

Evidence available from across all stakeholder consultation activities indicates that the problem and its drivers are likely to persist in the short- to medium-term without EU action. The imperfect information on qualifications obtained in another MS will continue to complicate hiring procedures for employers and mobile workers.

MS have made efforts to develop databases which facilitate comparability with non-national qualifications. 86 However, these national efforts would continue to duplicate work and cost time and resources for individual MS. The only current EU level database on qualifications is the Europass platform. However, without further measures its completion will be slow and its effectiveness as a tool for labour market actors to compare qualifications from other MS to national qualifications will remain limited.

Despite MS advancing in digitalisation efforts, progress remains uneven and risks producing a growing divide between early and late adopters. In the long term, in the absence of EU coordination and standards, fragmentation would persist and deepen as MS would adopt non-interoperable digital solutions 87 at varying speed and scope and digital credentials would not necessarily be accepted across MS because of lack of clarity on their legal status.

Technological developments, including AI-enabled solutions, are expected to facilitate certain aspects of cross-border qualification recognition over time, but they are unlikely to address the identified problems on their own. Current evidence suggests that AI is likely to complement rather than replace existing recognition processes. The Council of Europe survey of 138 recognition institutions 88 found that AI applications are currently used mainly for fraud detection, document verification and translation, while automated comparability assessments remain limited. The survey also identified barriers to wider deployment, including concerns related to data protection and security, legal certainty, technical expertise, funding, and the availability of high-quality, structured and trusted data. As further addressed in the section 5.1.1. of the Impact Assessment, AI relies on the availability of reliable and trusted information and cannot replace authoritative sources of qualification information. Consequently, official NQF databases and registers will remain essential as quality-assured reference sources for cross-border recognition. The Council of Europe further emphasises that AI should support, rather than replace, human decision-making in recognition procedures. While AI is therefore expected to support certain aspects of the recognition process, it is unlikely to remove the underlying barriers identified in this Impact Assessment.

Similarly, SPI Action 2 impact assessment's own baseline projection anticipates that the gradual uptake of digital credentials and authentication tools may reduce fraud risks in those MS and professions where such tools are fully integrated into administrative workflows, but that these improvements are unlikely to translate into system-wide efficiency gains, given the voluntary and non-binding nature of most relevant EU instruments and the continued reliance on hybrid or paper-based procedures in many jurisdictions. Fraud techniques are, moreover, becoming more sophisticated rather than less, with AI-based falsification identified as a growing complicating factor for CAs' existing manual authenticity checks. Left unaddressed, authenticity risk will therefore continue to generate both a direct administrative cost for CAs and a broader, harder-to-measure cost in the form of continued institutional caution towards qualifications obtained elsewhere in the Union, which in turn constrains the trust on which faster and less document-intensive recognition procedures depend.

Overall, if the current fragmentation of availability of digitalised, secured and interoperable information on qualifications and skills and the underlying imperfect information persists, EU workers are likely to continue experiencing less favourable conditions in accessing the labour market in other MS, and business are going to continue bearing higher costs when recruiting workers across the Single Market. The digital fragmentation in particular is estimated to become more costly each year, as MS that start to adopt digitalisation of credential systems will have no incentive to adopt a system which allows for full interoperability across the EU. Despite the EUDI Wallet rollout, the EU interoperability, and, thus, seamless portability of qualifications and skills across the EU, would not be guaranteed 89 .

3.Why should the EU act?

3.1.Legal basis

The initiative is based on Articles 45 and 46 TFEU which provide the legal basis for adopting measures to facilitate the free movement of workers. Pursuant to Article 46 TFEU, the European Parliament and the Council are mandated to adopt the necessary measures to bring about the freedom of movement for workers. This includes, inter alia, the systematic removal of administrative and legislative obstacles hindering the search, application for, and take-up of employment across MS (Article 46(b) TFEU), as well as setting up appropriate mechanism to bring offers of employment into touch with applications for employment and facilitating the balance between supply and demand and level of employment in the various regions and industries (Article 46(d) TFEU).

3.2.Subsidiarity: Necessity of EU action

The free movement of people is a fundamental principle of the European Union. To fully benefit from this right, individuals must be able to rely on the qualifications awarded in any MS when they apply for, take up or pursue a professional occupation in another MS. The digitalisation of qualifications will facilitate their portability across the EU only if it is carried out in a harmonised and interoperable way across MS. Solutions implemented by a single country will not ensure the benefits for the Single Market but rather deepen its fragmentation. The Commission initiative in this area is timely, because the EUDI Wallet will come into application at the end of 2026: the EUDI framework regulates and harmonises the issuance of attestations via a trust service and via public bodies (which can include issuance of education and training credentials). Moreover, some MS have already introduced or announced to introduce the possibility to request electronic qualifications under their jurisdiction (e.g. FR, FI, IT and ES). To avoid a situation where digitalised qualifications cannot be relied on in other countries due to a lack of interoperability, it is timely for the Union to act by adopting a measure harmonising digital qualifications across the EU. In absence of EU-level legislation, there is a risk that the differences between MS will deepen which could further exacerbate the existing obstacles.

3.3.Subsidiarity: Added value of EU action

Barriers related to qualifications and skills contribute to the existence of obstacles to the free movement of people who wish to work in another MS. They have a negative impact on the functioning of the single market by creating costs for businesses and individuals and indirectly affecting the potential of labour mobility in addressing labour shortages in the EU. Without improved information on qualifications and skills obtained in other MS and tools facilitating effectively the portability of such qualifications and skills, businesses and workers face difficulties when considering opportunities across the EU. Given the cross-border nature of these problems, effective solutions are best pursued at the EU level, rather than through individual efforts by MS.

The added value of ensuring availability of verifiable, secure, digitalised and interoperable information on qualifications and skills obtained in the EU is that EU citizens will be equipped with digital qualifications that are easily accessible to them as holders of qualifications, their potential employers and in case of regulated professions in accordance with Directive 2005/36/EC the recognition authorities in MS. Employers will also have access to tools enabling better understanding and comparison of qualifications issued in different MS. Thanks to the common legal and technical framework underpinning the digitalisation of qualifications, digital qualifications issued in another MS will become more trustworthy and easier to verify. Digital qualifications issued in a standardised manner will be understood everywhere in the EU. This in turn will make job applications less cumbersome and facilitate smoother access to jobs in all MS. While fully respecting MS’s responsibility for education and training, the expected added value of this action will be greater portability of qualifications and skills listed by MS in their national qualification frameworks and issued in a harmonised digital format.

Creating momentum in advancing European digital policies and contributing to transforming the EU into a modern, resource-efficient and competitive economy. An EU action will help accelerate the digitalisation of cross-border public services 90 , ensure a well-functioning, integrated digital single market, ultimately benefitting European competitiveness. By building on and reinforcing key digital EU initiatives - such as the SDGR, the Once Only Technical System (OOTS), and the EUDI framework – an EU action will maximise the impact of prior EU investments, being part of a coherent and cohesive EU digital landscape that serves the interest of the EU and its MS. If the EU does not act now, actions by MS would likely lead to fragmented, uncoordinated, incompatible solutions that fail to integrate with existing EU initiatives. This could result in suboptimal outcomes and be more costly to reverse at a later stage. An initiative in digitalising diplomas could furthermore pave the way for the adoption of similar solutions for other documents relevant for individuals and companies in cross-border situations.

4.Objectives: What is to be achieved?

4.1.General objective

The general objective of the initiative is to facilitate portability of qualifications and skills between MS in the context of free movement of workers. In practice, this means ensuring that labour market actors in the EU have access to simplified, effective and cost-efficient ways to carry, prove, read, understand and compare qualifications and skills obtained in another Member State.

This general objective builds on existing EU tools and solutions supporting the use of qualifications and skills across borders and is aligned with several Commission priorities. It responds directly to the agreed roadmap of the European Institutions to achieve “One Europe, One Market” to “strengthen the portability of qualifications and skills across national borders, including through digitalisation and interoperability”. It reinforces the simplification agenda of the European Commission by aiming at faster, less burdensome, digital-by-default processes for workers moving between MS. It also supports the EU Competitiveness Compass, which identifies retaining and mobilising talent across the EU as key to boosting the Union’s competitive standing, by ensuring that skills and qualifications acquired in one MS are readily usable in another. It further contributes to the European Pillar of Social Rights, notably its principles on fair access to employment and support for labour mobility, and the Single Market Strategy, which aim to remove remaining barriers to companies and workers operating across the EU. Taken together, these links position the initiative as a concrete step forward towards the completion of the Single Market, reinforcing the free movement of workers.

4.2.Specific Objectives

Specific Objective 1. By the end of the transition period, labour market actors have access to reliable and comparable information on skills and qualifications issued in the EU.

Specific Objective 2. By the end of the transition period, labour market actors in the EU can benefit from interoperable and verifiable digital attestations of qualifications and skills.

These Specific Objectives are further broken down into Operational Objectives (OO) in Section 9, where, considering the preferred Policy Option (PO), the means to measure them for a given timeframe are defined for monitoring and evaluation purposes.

The Specific Objectives 1 and 2 positively contribute to multiple SDGs: 91  

·SDG 8 (Decent Work and Economic Growth). Enhances labour mobility, improving job matching and equal opportunities (Targets 8.2, 8.3, 8.5).

·SDG 10 (Reduced Inequalities). Supports cross-border qualifications acceptance and reducing disadvantages faced by EU mobile workers (Targets 10.2, 10.3).

·SDG 9 (Industry, Innovation and Infrastructure). Strengthens digital infrastructure, interoperability and EU innovation (Target 9.1), aiding cross-border talent mobility.

5.What are the available Policy Options?

5.1.What is the baseline from which options are assessed?

This section describes the most likely evolution of the current situation in the absence of additional EU-level intervention. The baseline follows a 'no-policy-change' approach, incorporating existing and possible future developments in national, EU-level and global policies, as well as relevant Commission proposals not yet adopted by co-legislators. It builds on the policy and problem contexts described in Sections 1 and 2, and accounts for expected economic and social developments by drawing on available foresights and forecasts.

Availability of reliable and comparable information on qualifications

The EQF Council Recommendation will continue to invite MS to establish National Qualifications Frameworks, to reference them regularly against the EQF in a peer reviewed process, and to maintain registries of national qualifications connected to the Europass platform. However, whether MS do so will remain entirely at their discretion, which limits the value of the public good that aggregated, up-to-date, and comparable official information would otherwise provide. The effectiveness of the existing qualifications comparison tool on Europass will remain limited without continues and up-to date official information supplied by MS.

14 MS have already connected their national qualifications databases/registries with Europass and more MS with an existing database/registry may decide to connect with Europass (e.g. some MS are already testing the system). The update of the information, once the MS have connected their databases/registries, depends on the willingness of MS. The accreditation database for higher education is already connected with Europass.

The increasing role of AI in comparing qualifications

While AI-enabled tools are expected to play an increasing role in supporting the comparison, translation and verification of qualifications, they are unlikely to eliminate the underlying problem drivers identified in this initiative. AI systems can facilitate access to information and improve administrative efficiency, but they remain dependent on the availability, quality and interoperability of authoritative qualification data. 92 Where official, structured and up-to-date information is unavailable, incomplete or inconsistent across MS, AI systems are likely to reproduce these shortcomings and may generate inaccurate or biased results. 93  

Moreover, AI systems cannot, on their own, establish the authenticity of a qualification or confirm that a qualification is genuinely linked to the individual presenting it. 94 The future deployment of AI solutions in this area will also take place within the framework established by the AI Act. 95 In particular, AI systems used in education, vocational training and employment are subject to specific requirements where they qualify as high-risk AI systems, including obligations relating to risk management, data quality and governance, transparency, human oversight, accuracy and record-keeping. Actually, workers whose qualifications are issued in non-standardised formats, or whose credentials are less readily interpretable by automated systems, may consequently be disadvantaged in digital recruitment. 96 The safeguards of the AI Act are expected to support the trustworthy deployment of AI in qualification-related processes, but they do not remove the need for reliable, quality-assured and interoperable qualification information and verifiable digital credentials, which remain the primary objective of this initiative.

Interoperability of digital attestations

While digital tools hold promises for improving the comparability and verification of qualifications, uneven and uncoordinated adoption in MS is expected to deepen rather than resolve fragmentation across MS. Most credentials will likely remain paper-based or non-verifiable, and without EU-level coordination on semantic frameworks, data standards, and IT infrastructure, cross-border interoperability will remain limited as none of the MS has an incentive to act as first. Some MS have already established digital diploma registers, digitalising their diploma archives, while some MS may take other approaches: keeping archives decentralised or creating digital archives for recent documents only. Please refer to Annex 8 for a full breakdown of the information by MS. MS will continue implementing the Single Digital Gateway Regulation (SDGR) and the Once-Only Technical System (OOTS). It is expected that they will finalise the provision of fully online procedures for the three studying procedures, which will lead to the connection of evidence providers related to qualifications information between public institutions. The digitalisation of diplomas is not explicitly covered by the SDGR 97 and will likely be even more limited and fragmented. In addition, the format of the documents is expected to remain diverse as the SDGR provides MS the flexibility to choose their own output format (e.g., PDF, structured data), while still adhering to certain requirements.

Independently of the SPI, MS will progressively make available standardised EU Digital Identity wallets to all EU citizens and residents by December 2026 98 . EUDI Wallets will provide a safe, reliable, and private means of digital identification for everyone in Europe. Every MS will provide at least one wallet to all its citizens and residents allowing them to prove who they are and securely store, share, and sign important digital documents (such as an ID card or a driving licence). This IT infrastructure is therefore considered to be part of the baseline for this initiative. However, whilst the eIDAS 2.0 impact assessment 99 highlighted educational qualifications as a key sector benefiting from the EUDI Wallet rollout 100 , the eIDAS Regulation 101 only covers personal identity, the legal trust framework and the general wallet functionality. It is not guaranteed that all MS will use it to digitalise qualifications and skills. Furthermore, those MS that do choose to use it will have the freedom to choose the scope, the layout, the content and the underlying technical format of their qualifications making interoperability increasingly difficult. The DC4EU large-scale pilots clearly demonstrated the business case for a harmonised approach across the education and training landscape in order to facilitate cross-border use. Unilateral actions - without EU level legal harmonisation of the sectoral use particular sectors to ensure uniformity in formats, standards and rules - could pose challenges regarding the acceptance and verification of these documents in other MS with consequences for individuals and employers.

The EUDI Wallet will be free of charge for citizens to use. Relying parties (the public and private entities that wish to request or verify credentials from a citizen's wallet) will instead be subject to a mandatory registration process. Depending on how MS implement this at national level, this registration may involve moderate administrative costs or fees, though the precise cost for relying parties is still being defined in several MS.

The Interoperable Europe Act establishes structured EU cooperation on interoperability, introduces mandatory assessments to evaluate the impact of changes in IT systems, promotes the sharing and reuse of interoperable solutions through the Interoperable Europe Portal, and provide innovation and support measures for policy experimentation. As a horizontal framework, its implementation alone will not resolve the cross-border sector-specific challenges identified in the report.

The Europass EDC infrastructure already enables education and training providers to issue digital learning credentials and allows users to store them in their Europass wallet. However, the current uptake is not expected to improve or increase, as those who bear the burden of issuing digital qualifications (education and training providers) are not necessarily the same actors who benefit most from them (those who need to understand and verify the qualifications, such as employers). As with the EUDI Wallet, it is not guaranteed that MS which independently choose to digitalise their qualifications will select Europass as their IT infrastructure.

Demographic ageing and labour shortages

Demographic ageing and shrinking working-age populations are increasing the pressure on employers, particularly in shortage sectors, to recruit across borders. Many are already responding by accepting non-national qualifications even if they do not fully understand them and use digital tools to verify them informally. However, these ad hoc solutions are inconsistent and unreliable in the absence of common standards. This will leave EU talent underutilised and constrain the Single Market's capacity to match skills to labour demand, even as demographic pressures make such matching increasingly urgent.

5.1.1.Key figures and considerations in the baseline

Different levels of digital readiness for MS

MS are assumed to have different levels of digital readiness in the baseline. This digital readiness is expressed as a probability (from 0 to 1) and relates to issuing digital qualifications as verifiable credentials into a wallet or a fractional percentage readiness for database connection.

On the one hand, there is the probability of MS adopting the baseline of issuing digital qualifications as verifiable credentials into a wallet. It is based on the analysis carried by DC4EU as well as additional analysis on MS readiness (see section 2.3 and point 5 in Annex 8 for more details). In particular, the clustering into four groups related both to their EUDI Wallet readiness and readiness to issue digital qualifications, the adoption of other joint IT systems (such as EMREX), actual participation in DC4EU, the existence of diploma registers and the MS topology of issuance contribute to the probability factor.

On the other hand, there is the database connection readiness of MS. MS which already have a connected database in the current ELM format receives the highest level of readiness (while not 100% as SPI will also introduce the awarding body and accreditation information, which can be combined with the qualifications information); MS with a database not connected to Europass receives a lower score and MS without any database receive the lowest readiness score.

Table 1 Levels of digital readiness per Member State 102

Number of verifications of qualifications issued in another Member State

As previously underlined, the individual decision-making processes of employers cannot be observed, nor aggregated. The number of qualifications issued in another Member State that employers verify each year must therefore be estimated.

The annual flow of EU mobile workers is approximately 957,000 103 . It is assumed that companies requiring qualifications when advertising a vacancy and/or as part of the application process will verify at least the authenticity of the qualification of the selected applicant.

An ad-hoc query of the Skills Online Vacancy Analysis Tool for Europe yield that 23% of online vacancies include at least one wording directly related to qualifications. In the SME Pannel 29% of respondents declared that they request qualifications when hiring. Applying these percentages to the annual flow of EU workers yields an estimated range of 220,110 - 277,530 qualifications issued in another MS verified per year.

This estimate can be considered as conservative as it takes as a basis only the flow of mobile workers (hence mobile workers who apply to change jobs in the MS they already reside are not counted) and does not include cross-border workers 104 .

Number of comparability statements for qualifications issued in another Member State

The estimate is based on an ENIC-NARIC survey on the number of comparability statements processed by MS. Since survey coverage was incomplete, responses are weighted by each Member State's share of the inflow of other EU citizens (2019–2023), and missing values for non-responding MS are extrapolated using the average of those that did respond. This produces an estimated total of 196,261 comparability statements annually. Since only about half of these concern EU citizens, the figure is halved to roughly 98,000, then rounded down to 90,000, which is used as a deliberately conservative baseline estimate.

Number of education and training providers in the EU that issue qualifications relevant for the labour market

Both VET and HE institutions are counted as providers issuing qualifications relevant for the labour market. For VET institutions, two methodological approaches are used to produce the lower and upper bounds of the range: a conservative approach and a comprehensive approach. The conservative approach entirely excludes specialised schools and, for mixed-curriculum institutions offering both vocational and general education, applies a 50% weighting factor to balance the representation of programmes; this yields a baseline of 27,762 VET institutions. The comprehensive approach includes specialised schools and counts mixed-curriculum institutions at full (100%) capacity, yielding 39,328 VET institutions.

For VET, institutions were further categorised into Public and Non-Public, with government-dependent private and private institutions consolidated into the non-public category; no equivalent public/non-public distinction was made within the HE sector. VET data is drawn from Eurydice 105 , while HE data is drawn from EQAR's Higher Education Institutions (HEIs) dataset 106 , with both datasets relating to 2024. One exception applies to Hungary, where the public/non-public distinction for VET schools could not be applied. Combining VET and HE figures, the final estimated range of education and training providers considered is 32,788 - 44,354. The full matrix of education providers by VET and HE institution, including source data and detailed methodology, is presented in Annex 8(7).

Table 2. VET and HE providers per Member State

To convert institution counts to awarding-body counts, different awarding-governance models across MS are considered, as shown in Annex 4.1, Table 23. Upper secondary schools offering only general programmes are excluded from the institution count, as they already share grade results electronically with the awarding body today 107 . Instead, they are captured via the (mostly centralised) awarding bodies for secondary school qualifications, based on a simplifying assumption of an average of 2 'school certificate' issuers per Member State. This reflects the range of national governance models, from a single centralised issuing authority (e.g. a Ministry of Education) to a split between school-level and state-level issuers (see e.g. Eurydice, National Education Systems, 'Assessment in general upper secondary education,' country reports 108 ) and is used here as a working estimate rather than an empirically derived EU-wide figure.

Number of non-NQF micro-credentials providers

The number of non-NQF micro-credential providers cannot be directly quantified, as no official EU-level repository of private and non-formal issuers for micro-credentials currently exists. Cedefop's mapping study 109 confirms this gap, noting that EU-level data are lacking due to the diversity of providers and national systems. In the absence of such data, the approach taken here relies on modelling, using available proxy indicators to assess the size of the provider landscape. As detailed in Annex 4.1.1, this draws on membership data from the Lifelong Learning Platform (LLLP) 110 , whose networks represent over 60,000 organisations across formal, non-formal and informal learning, adjusted to exclude formal education and training institutions already captured as qualification issuers.

Given the absence of a representative dataset, the resulting estimate of 45,000 non-formal and informal learning organisations should be treated as indicative rather than precise, while the input parameters used to derive it carry a significant degree of uncertainty. This uncertainty stems both from the proxy nature of the underlying data (LLLP membership figures were not designed to measure micro-credential provision specifically) and from the assumptions applied to disaggregate that membership by provider type. Eurostat data showing that 67.4% of EU enterprises with 10 or more employees were "training enterprises" in 2020 111 further suggest that the true pool of potential providers may extend considerably beyond this estimate.

5.2.Description of the Policy Options

Three policy options are considered for detailed assessment. They were identified based on the analysis of technical feasibility, Member State readiness and the state of development of key EU level tools such as the EQF, Europass and EUDI Wallets.

Some elements to facilitate the understanding of the options

·Options refer to two categories of documents: i) ‘qualifications’ is used for any document in an NQF as well as formal school, VET and higher education diplomas predating the establishment of NQFs and ii) ‘other skills document’ refers to documents not included in the NQF which also signal a person's skills, such as micro-credentials from non-formal training courses 112 , or Diploma Supplements. Any of the two categories of documents can have EQF levels 2-8 (i.e. all formal education certificates and diplomas from lower secondary VET education to PhD 113 ).

·Two tools are considered to digitalise qualifications: i) the EUDI Wallet: Its introduction will significantly improve the way electronic documents are exchanged in the EU. The DC4EU project showed that it is a viable option for the digitalisation of qualifications; and ii) the Europass Wallet: The European Digital credentials for Learning (EDC) is an infrastructure that is available to issue digital credentials in the field of learning. Its use by issuers is currently voluntary and the tool is mostly used today to issue non-formal micro-credentials. For citizens, both EUDI Wallet and the Europass Wallet are voluntary and free of charge. and the use of the applications is entirely up to the individual’s decision. The European Learning Model, which has been assessed according to the Common Assessment Methodology for Standards and Specifications (CAMSS) 114 will be the semantic foundation for the digitalisation of qualifications and the comparison tool under all options.

Any delays by MS in the implementation and rollout of the EUDI Wallet (by end of 2026) would not directly affect the timeline and success of the Skills Portability Initiative. Even if the Wallet constitutes part of the baseline infrastructure on which this initiative relies, the Skills Portability Initiative has a transition period that would offset any implementation delays. Nonetheless, the calculations underpinning this impact assessment have adopted a deliberately conservative approach to the projected uptake of the EUDI Wallet, in line with the assumptions used in the impact assessment for ESSPASS 115 . This conservative approach ensures that the estimated costs and benefits of the Skills Portability Initiative are not overly dependent on an optimistic rollout scenario and helps mitigate the risk that gaps or delays in MS' implementation of the Wallet could undermine the validity of the assessment's conclusions. For the Europass Wallet, this conservatism is further reinforced by an additional factor specific to its scope: unlike the EUDI Wallet, which will be used to hold a broad range of credentials such as national ID cards and driving licences, the Europass Wallet is dedicated specifically to learning-related credentials, meaning its uptake trajectory is likely to be more gradual and cannot rely on the pull of other, more frequently encountered use cases. In addition, for both wallets, the calculations only count Year 1 as starting after the three-year transition period foreseen for this initiative, which further limits the projected uptake figures used across the assessment.

Table 3 Cumulative wallets uptake (conservative assumption)

·“Automatic” issuance of digital attestations means that the proof of qualification would be issued into the user Wallet instantaneously, without manual processing. The “on demand” issuance of older qualifications means that an exchange between various actors is needed to issue a qualification, using the SDGR mechanism or a manual verification process.

·Roles of different bodies in in issuing of digital attestations:

othe education and training providers, they provide the training and gather the results of their learners and, share the data with awarding bodies ahead of the issuance of a qualification (unless they carry both roles),

othe awarding bodies, the formal bodies/authorities that award the qualification to a learner. They, either issue the qualifications directly or use an issuer (in the same way they may rely on the national printing house) for the actual creation of the paper proof. Some MS have also developed diploma registers to facilitate this process  116 .

othe issuer of the digital document, which is in charge of creating the digital document.

oUnder all options, the organisation of the issuance process would depend on the MS organisation, for example regional structures or chambers of commerce and industry could continue to play a role similar to the role they play today.

·In all options newly issued qualifications would be digital by default, consistent with the vision established in the Commission's 2030 Digital Compass Communication. This is also coherent with SPI Action 2 which relies (1) on the swift issuance of digital qualifications and (2) on a high level of reliability regarding the authenticity and the identity of the awarding body and of the qualification holders. Each of the options considered has considered this dual requirement, ensuring that speed of issuance is not achieved at the expense of verifiability, or vice versa.

Design of the policy options

The policy options were formulated in a manner to allow comparison between key parameters for the approach to digital attestations of qualifications:

·the choice of the specific tool: two options (PO1 and PO2) rely on the EUDI Wallet. On the other hand, PO3 relies on the Europass wallet.    

·the scope of digitalisation: all options include documents most relevant for the labour market and quality assured through the NQF (EQF levels 2-8, including some more formalised micro-credentials which have fulfilled NQF quality assurance criteria set by the MS). Two options (PO1 and PO3) are even broader and include also other skills documents, notably micro-credentials outside the NQF – these are of growing importance in the labour market but are less formalised and are not quality assured in the same way as NQF documents. 117

·The time window of information covered by digitalisation: Two options (PO1 and PO3) consider the digitalisation of all the past qualifications and skills documents “on demand” and one option (PO2) in addition extends the automatic issuance as far as possible to the previous 10 years on demand. 118 Digitalising past documents is important to meet objectives, as it benefits larger share of the existing workforce. In all options past qualifications are only issued to support workers access employment in another MS. New qualifications do not have the same limitation because for new graduates it is more difficult to establish what the primary use of the qualification would be (national or EU labour market or further education).

The POs are built in a complementary manner and are mutually exclusive. All retained options are legislative, as the achievement of a standardised approach to digitalisation requires making some elements obligatory for MS and issuers.

Table 4: Overview of Policy Options

All the options share some common elements and supporting measures (proc) are envisaged to accompany all three options. In particular, awareness of the opportunities related to the availability of digitalised information on qualifications could be raised through promotion campaigns at EU, national and regional levels. In addition, MS could be encouraged to make use of available funding at EU and national levels, e.g. to fund their digital transformation. Moreover, the Commission would continue the support to the implementation of existing tools and initiatives (EQF, Europass, the Council Recommendations on validation of non-formal and informal learning, and on the EU approach to micro-credentials and the Europass Decision). These measures are not assessed for the costs and benefits as they are either ongoing efforts or voluntary initiatives and choices of the MS.

Detailed description of the options

PO1

This option uses EUDI Wallet as the tool to issue digital attestations of qualifications (see visualisation in Annex 11).

It has a broad scope: qualifications (included in an NQF and covering EQF levels 2-8) and other skills documents. 

All new qualifications would need to be issued “automatically” – i.e. without delay, and without the need for manual processing. Issuance would follow a different model between public issuers and private issuers, having to rely on a qualified trust service provider 119 . They would be issued according to the trust framework of linking qualification, accreditation and awarding body information into the credentials.

Regarding qualifications awarded before SPI and no later than 45 years 120 prior, they would be issued digitally on request of the citizen for cross border purposes and within a reasonable time allowing MS time to gather the data and check the information (no later than two weeks when those qualifications are requested as part of a professional recognition procedure as described under Directive 2005/36/EC). As part of the eIDAS Regulation, MS shall already ensure that measures are taken to allow qualified trust service providers of electronic attestations of attributes to verify by electronic means, at the request of the user, the authenticity of the educational qualifications, titles and licences. In order to issue digitally qualifications that have already been awarded to workers and jobseekers in a paper and/or PDF format, MS would be able to leverage the Single Digital Gateway and the OOTS common services to check information before issuing a digital qualification in the EUDI Wallet 121 and rely on trusted information. The content of the qualifications would differ between the new and existing qualifications, so that MS can provide the necessary information, with many fields being optional (see Annex 11.5). 

For other skills documents outside NQFs (e.g. micro-credentials, Europass Supplements), new ones would be issued digitally to the EUDI Wallet by default, while existing ones would be digitalised only upon request.

Based on consultations and the DC4EU project a common framework of obligatory and optional data fields is identified for the new qualifications and skills documents (see Annex 11.4), to facilitate common understanding and comparability of the available information. The content of the older qualifications would be more limited, so that MS can provide the necessary information, with many fields being optional (see Annex 11.5). 

PO2

This option uses EUDI Wallet as the tool to issue digital attestations of qualifications.

It has a narrower scope: only qualifications (included in an NQF and covering EQF levels 2-8). This option excludes other skills documents for reasons of practical implementation (the landscape of micro-credentials is very diverse, with a high number of issuers and less stability than formal qualifications), lower level of quality assurance and relatively lower value in the labour markets as they signal a narrower scope of skills.

The issuance of new qualifications into the EUDI Wallet would be the same as in PO1. The same mechanism as what is foreseen for older qualifications in PO1 is used here for qualifications issued more than 10 years before the SPI and up to 45 years before.

As PO2 focusses on labour market relevant qualifications, this PO also considers however a more generalised digitalisation of the qualifications issued in the past 10 years 122 . The more general digitalisation effort would ensure that more workers would be covered by this new opportunity, and more employers could benefit from time saving. 10 years is considered the maximum time allowing for the proposed reliance on consistent quality assurance through NQFs, since 2017 was the year when the new EQF Council Recommendation was adopted.

The qualifications from the previous 10 years would need to be issued automatically to the extent possible and in any case within a reasonable timeframe into the EUDI Wallet 123 . To ensure proportionality, this service would be provided only when requested by workers for the purpose of labour mobility, provided that they have an EUDI Wallet. The main efforts would be for MS to connect the databases containing qualifications, awarding bodies and accreditation information from the previous 10 years (thus providing the trust framework for the EUDI Wallet) so that the information for the automatic issuance would be available upfront. In many MS, this information would be available according to the state of play on NQF implementation presented with the proposal for the revision of EQF Recommendation in June 2016 124 while in certain cases, MS would need to either to still digitalise this information or collect the information. 125 Several MS record the information of individual diplomas 126 and a few countries 127 already have such a register 128 . This information was taken into account when considering feasibility of this approach. The verification of these qualifications would then align with the trust framework of the new qualifications and would present the same level of trust and authenticity.

To the extent possible, MS would have to have the same level of content description of qualifications of the past 10 years as for new qualifications and should use the same trust framework 129 - see Annex 11 130 . However, implementation of this option would include some mitigating measures ((1) introducing more flexibility in the data fields, for example using the same data fields as older qualifications regarding the description of the qualification while maintaining the same trust framework; (2) not requiring the automatic issuance of the digital qualification and aligning with the time needed for MS to access information with older qualifications).

The extension of the automatic issuance to the last 10 years is an important element of this option and to ensure that its feasibility is fully considered, a sensitivity analysis was conducted to compare the costs and employer savings compared to no such special treatment for the backlog (see Annex 4).

PO3 

This option uses the alternative tool (Europass wallet) to issue digital attestations of qualifications.

It has the same broad scope as PO1: qualifications (included in an NQF and covering EQF levels 2-8) and other skills documents. 

The digitalisation would take place by issuing new digital documents by default in the Europass wallet, thus leveraging the existing Europass framework that would be further updated for supporting mass issuance of documents across the whole EU. Issuers would be able to make use of the European Digital Credentials for Learning (EDC) infrastructure to issue qualifications, where the key requirement is to have an electronic seal that is eIDAS compliant. The EDC infrastructure would rely on the same trust framework as PO1 and PO2, which is hosted in Europass. Individuals would store their digital credentials in the Europass wallet.

New qualifications would be issued automatically. Past qualifications awarded before SPI and no later than 45 years before would be issued into the Europass Wallet upon demand and for the purpose of employment in another MS. These qualifications would have to be issued within a reasonable time, and no later than two weeks when those qualifications are requested as part of a professional recognition procedure as described under Directive 2005/36/EC, thus allowing MS time to gather the data and check the information (data to be included is described in Annex 11.5). For other skills documents outside NQFs (e.g. micro-credentials, Europass Supplements), new ones would be issued digitally to the Europass wallet by default, while existing ones would be digitalised upon request 131 .

Contrary to the EUDI Wallet, the Europass wallet does not provide any link to the identity of the account holder and does not provide the same level of authenticity as the EUDI Wallet since the eIDAS Regulation brings a complete trust framework for ensuring trustworthiness of (qualified) issuers, identity of wallet holders and the registration of all parties who are interacting with the ecosystem and sets standard protocols and interfaces. On the other hand, the Europass platform is the EU platform for career management and in that option, the platform would evolve for improving the authentication of digital credentials issuers 132 .

Regarding the obligatory and optional data fields the requirements would be the same as in the other options, with a more comprehensive set for the new documents (see Annex 11.4), and a more limited set for the older ones (see Annex 11.5). 

Common elements

Under all options, MS would need to give legal value to the qualifications and other skills documents issued digitally and recognise the legal value of digital qualifications and skills documents issued in other MS. This ensures legal interoperability of the digital attestations.

All options include the same approach to NQF and EQF: it would become mandatory for MS to have a comprehensive NQF, and for their NQFs to be clearly and regularly referenced to the EQF. The NQF and EQF are important to ensure that the digitalised qualifications are quality assured and comparable. The EQF peer review process ensures a level of mutual understanding of qualifications levels from another MS, of qualifications types in different MS and brings trust of the qualifications that become included in the framework. The EQF brought a learning-outcome approach to the description of qualifications which brings the necessary information to employers in terms of knowledge, skills and responsibility and autonomy of the qualifications’ holders. Such an approach can help employers better understand what an applicant can do based on these comparable descriptions and can have trust that the qualification had a minimum level of quality to become part of the NQFs, which can strengthen the signalling aspect of the qualifications. MS would be obliged to include the EQF level in all new qualifications that are issued in their territory, as it would be a mandatory field in the digital qualification. In addition, MS would be encouraged to use skills and knowledge concepts from the ESCO classification, as an optional field to complement the mandatory description of the learning outcomes 133 .

Figure 2 The reinforced trust framework required for qualification attestations

While the EUDI Wallet framework provides legal proof of origin in terms of the issuance of digital attestations, it does not, by default, provide proof of authorisation to award or issue. In order to ensure that digital qualification attestations are only awarded and issued by authorised bodies it is necessary to supplement the EUDI Wallet Trusted Lists with an additional trust framework, specifically for qualifications. This reinforced trust framework encompasses databases of qualifications, awarding bodies and accreditations, which are connected to Europass  134 . At the time of attestation issuance, these three data elements will be triangulated, combined with the issuer information and cryptographically locked into the digital qualification attestation as referenceable information. This information can be subsequently verified independently by employers, using the verification software. As part of the EQF Recommendation and the Europass Decision, MS are already invited to provide comprehensive and up-to-date information on qualifications. Transforming this invitation into an obligation under all the options would be needed to have a robust trust framework for the digital qualifications and for the access to publicly and reliable information on qualifications standards. In all POs, MS also need to provide information on awarding bodies and accreditation in order to complete the trust framework described above. The information on awarding bodies is available in some qualifications databases already (when a qualification can only be awarded by a single awarding body). Accreditation is available for higher education thanks to the connection with the European Quality Assurance Register 135 and during a consultation of EQF AG members in June 2025, MS clarified that inclusion into an NQF is considered a form of accreditation and that accreditation can take many shapes but could be referenced in future digital credentials.

Figure 3 Approach for historical qualifications that fall outside the trust framework

For historical qualifications, such a comprehensive trust framework will not be available, and in these cases the issuer will need to rely on an alternative method of instilling trust in the attestation in order to complement proof of origin provided by the EUDI Wallet Trusted Lists. Here, the issuer will be required to embed evidence of accreditation and optionally embed a copy of the original qualification document into the digitally signed attestation. Once signed, the embedded evidence is cryptographically locked into the attestation and will be tamper-evident at the time of verification by employers.

For the information in the Wallets to be easily readable and verifiable, employers need a specific viewer/verifier application, and the provision of such an application is foreseen under all the options. In case of the EUDI Wallet POs a generic verifier exists (and can be used for the development of a reference software) but it would need to be adapted to the needs of a specific sector in terms of rendering the information in a useful way for employers and of providing verification of the sectoral trust framework of the credentials. In case of the Europass Wallet, EDC also includes a viewer/verifier that allows employers to view credentials and know instantly if the credential has been tampered with.

To support the two specific objectives, under all options the Commission would also provide on the Europass platform a reinforced qualifications comparison tool, which would bring together the existing comparison of qualifications framework and comparison of single qualifications tools together as well as a tool to find your EQF level based on your qualification title for an improved user experience. The outcome of the comparison could be exportable so that a jobseeker can attach it to their applications, for information purpose only. The comparison of qualifications would be instrumental to ensure that employers can access comprehensive information on the content of qualifications beyond the information presented in a diploma. The tool would allow users to use a search, for example to find easily the national qualification(s) that are similar to another qualification or even class of qualifications from a different MS.

In all options MS would remain free regarding the qualifications that they include in their NQFs, and they would keep the possibility to include micro-credentials or not to their NQFs. However, micro-credentials included in NQFs would need to follow the Council Recommendation on the EU approach on micro-credentials to the extent possible.  136

The implementation of all the options would require some transition periods to implement. The transition period would give time for the MS and the issuers to prepare the necessary infrastructure. In addition, implementing acts would need to be prepared during that time to clarify technical implementation details (e.g. related to formats, semantic model), the eIDAS rulebook would need to be finalised (based on a current DG CNECT-DG EMPL internal pilot) and adopted for PO1 and PO2 or the Europass issuer updated in the case of PO3. The Commission would also organise a pilot during this preparation phase to ensure all standards and rulebooks are aligned with the issuers and verifiers’ needs and update specifications if needed. This transition period is estimated to be three years in after the adoption of the initial legislative act.

5.3.Options discarded at an early stage

A number of policy measures considered at the preparatory stages of this initiative or put forward in the consultation process have been discarded without a detailed assessment of their impacts, either because it was not possible to establish sufficient evidence to confirm the issue that those measures would have aimed to address, or because the measures were unsuitable to achieve the policy objectives, clearly disproportionate, or incoherent with the existing legal framework. For more detail, see Annex 9.

·Setting up a European wide system of quality assurance of qualifications (discarded for reasons of proportionality and lack of competence at EU level on education and training)

·Harmonisation of the content and of the organisation of MS’ education and training systems (lack of competence at EU level)

·Forbidding the issuance of paper credentials (discarded due to proportionality, legal feasibility and inclusivity reasons).

·Limiting the digitalisation of qualifications to qualifications leading to regulated professions (discarded due to the difficulty of implementation and lack of harmonisation at EU level)

5.4.Intervention logic 

The intervention logic of the initiative is based on the premise that companies face uncertainty about the expected productivity of job applicants. Qualifications serve as a signal, reducing the imperfection of information of employers. However, when qualifications have been obtained in another Member State, the value of this signal is weakened because employers (and other labour market actors) may understand less the level, content of the qualifications, and may have doubts about its authenticity. In a context of imperfect information in cross-border hiring, this weakened signal makes it more difficult for EU mobile and cross-border workers to have their skills and qualifications understood, trusted and effectively used in another Member State.

The initiative addresses two interrelated underlying causes of information asymmetry. First, it aims to improve the availability and accessibility of reliable and comparable information on the content, level and learning outcomes associated with skills and qualifications obtained in another Member State. This is intended to make skills and qualifications more understandable and comparable for employers and other relevant labour market actors, thereby strengthening their signalling value across borders. Second, it aims to facilitate the efficient proof and verification of the authenticity of qualifications and skills credentials through interoperable and verifiable digital attestations. This should reduce uncertainty and verification costs, while increasing trust in credentials presented across borders. By addressing these two dimensions of imperfect information in parallel, the initiative is expected to improve the portability of qualifications and skills and, ultimately, facilitate the matching of workers with employment opportunities across MS.

The intervention logic is structured around the two specific objectives. SO1 addresses the information asymmetry concerning the content and level of skills and qualifications by ensuring that labour market actors have access to reliable and comparable information. SO2 addresses the information asymmetry concerning the authenticity and technical verifiability of skills and qualifications by enabling interoperable and verifiable digital attestations. Together, these objectives are expected to strengthen the signalling value of skills and qualifications across borders, reduce the uncertainty and transaction costs faced by employers and other labour market actors, and make it easier for workers to carry, prove and use their skills and qualifications when moving between MS.

The identified POs respond to those objectives and each of them, when implemented, would cover all the elements of the identified problem:

-Information on the level and content of qualifications and skills will be provided in a structured and systematic way in the workers’ digital qualification attestation, and additional information on how the content compares to familiar, national qualifications will be made available through the Europass comparison tool

-Reliability of the information will be ensured through the reliance on MS NQFs, which also give assurance of quality of qualifications concerned

-Comparability of the information will be ensured through the reliance on the EQF, which already provides a translation between qualifications from various MS and will be additionally reinforced by making some of its elements mandatory; as well as standardisation of information provided through the digital attestations and in the Europass comparison tool

-Authenticity of the information will be, in case of new qualifications, instantly verifiable, and in case of older qualifications verification it will be facilitated

-Interoperability will be ensured through setting common legal, technical and semantic standards for the digital attestations.

6.What are the impacts of the Policy Options?

The expected economic and social impacts of the POs are assessed below. While economic impacts are mainly monetised, social impacts on employment and labour mobility, working conditions, social inclusion and fundamental rights are assessed qualitatively. Environmental impacts are also considered. The dynamic baseline scenario is described in chapter 5.1 and considered in this chapter as a reference point for the IA of each option.

6.1.Economic impacts

6.1.1.Direct costs

In essence, Action 1 of the Skills Portability Initiative requires an initial investment from administrations (both the European Commission and the MS) to set up everything needed to issue interoperable digital attestations for qualifications, to provide verifier software for these digital attestations, and to make official information on qualifications publicly available for the benefit of labour market actors who use these qualifications across borders. This investment will also carry associated maintenance costs over time. As discussed in the section below, this investment from administrations will have positive effects in any context where qualifications may have signalling value.

Other than this, PO1 and 3, which cover all skills documents beyond NQF qualifications, will also generate costs for providers of non-NQF micro-credentials. As defined in the Council Recommendation on an EU approach to micro-credentials 138 , these providers can include employers, trade unions, civil society organizations, public employment services, and any other actor that delivers a short learning experience and issues a micro-credential certifying its learning outcomes. Under PO 1 and 3, these issuers of non-NQF micro-credentials will also be required to issue digital attestations for their skills documents.

Therefore, except if they take on a role as micro-credentials providers, neither workers nor employers bear any direct costs (one-off or recurrent) related to the three policy options presented, nor do they hold any implementation obligations. The success of the initiative is, of course, linked to the uptake of the tools, both the use of digital attestations for qualifications and the comparison tool, since these will only be used if they are considered to have value for workers and employers. As discussed in section 5.2., the cost assessments have applied conservative assumptions for the uptake of the wallet, in line with the Impact Assessment for ESSPASS.

However, most respondents, both individuals and businesses, to the public consultation and the SME panel indicated that they were likely or very likely to use digital qualifications. In the public consultation, 91.9% of EU citizens (272 out of 296 respondents) and 91.3% of businesses (21 out of 23 respondents) indicated they were likely or very likely to do so. In the SME panel, this figure was somewhat lower, with 71.7% of SMEs (114 out of 159 respondents) expressing the same likelihood.

6.1.1.1European Commission

Costs of the comparison tool in Europass

The European Commission will bear the costs of making a more user-friendly NQF and qualifications comparison tool available to the wider public through the Europass website. However, this comparison tool 139 already exists under the baseline scenario, and its revision, maintenance and further improvement are covered by the contract managing the suite of Europass tools (including, for example, the CV builder 140 ). Considering experts criteria and the overall volume of this ongoing contract, a one-off cost of €300,000 and recurring maintenance costs of €15,000 for improving the comparison tool to address the objectives of the SPI can be attributed to the initiative, which is common to all three policy options.

Cost of the back-office tool connecting national databases

The European Commission will need to provide and maintain a back-office tool connecting all national databases. This tool is the backbone of the trust framework for the EUDI Wallet and the Europass Wallet. Besides, it also feeds reliable information into the comparison tool in Europass provided by the European Commission.

This back-office tool is built and maintained as an EU-side shared database, which covers the trust registry and catalogue infrastructure underpinning the system. Building this database means according to the experts’ criteria a one-off cost of €2,500,000, covering the trust registry, catalogue population as set out in Implementing Regulation (EU) 2025/1569, and the reference implementation. This figure is the same regardless of which issuance option is chosen, since the database constitutes the shared trust-framework infrastructure rather than something built separately for each option. Under the baseline scenario, by contrast, the one-off build cost for the NQF database is set to zero, and the ongoing costs are instead captured within the annual costs. Ongoing technical maintenance is calculated as 0.18% of the build cost annually, consistent with the maintenance-rate convention used elsewhere in the model. In addition, SPI requires €400,000 per year for EU-side coordination and governance: day-to-day running of the shared database, including onboarding support for MS, data-quality monitoring, and EDICG-style coordination. This coordination cost is genuinely additional to technical maintenance and is assumed to be zero under the baseline, since no SPI-wide coordination effort would be needed without SPI. The baseline scenario instead has its own annual running cost of €400,000, covering both IT and support costs for maintaining existing tools such as ETER and DEQAR.

Table 5: Cost for the EC to provide a back-office tool to connect national databases

Figures are expressed in millions of euros.

Costs of the reference verifier software

Under PO1 and PO2, which rely on the EU Digital Identity (DI) Wallet, the European Commission may develop and maintain a reference verifier software for the wallets. This reference verifier should demonstrate the required business rules to verify digital attestations consistently across MS, and to give national authorities a common technical basis on which to build their own verification services, rather than developing this capability independently. As no equivalent verifier currently exists for this purpose, it must be built from scratch, at a one-off cost of €1,500,000, according to experts’ criteria. This covers core functions such as credential parsing, signature validation, status-list and revocation checking, and accreditation-database lookups. Maintaining the reference implementation is estimated to cost €100,000 annually, covering both keeping the implementation current and providing central support to MS as they deploy it.

Under PO3, which relies on the Europass Wallet, the verification infrastructure builds on the Europass European Digital Credentials (EDC) verifier already operated by DG EMPL, rather than requiring a new reference verifier as under PO1 and PO2. As this system already underpins around 76,000 credentials issued to date, EDC experts estimate a one-off cost of €500,000 covers adapting it to add accreditation-database lookups and NQF schema validation, rather than building the underlying infrastructure from scratch. The annual maintenance cost of €450,000 reflects ongoing maintenance of the verifier (€125,000), first-line support (€100,000), second-line support (€100,000), and business support (€125,000). Because this approach extends an existing, operational system rather than building a new one, both the one-off and annual costs are substantially lower than the equivalent reference verifier costs under PO1 and PO2.

Table 6: Cost for the EC to provide a reference verifier software

Figures are expressed in millions of euros.

Costs to support non-formal providers of micro-credentials

Under PO1 and PO3, providers of non-NQF micro-credentials will also be required to issue digital attestations for the skills documents they provide. The European Commission will incur costs to support non-NQF micro-credential issuers.

Micro-credentials that are not included in National Qualifications Frameworks will not fall within the trust framework established for qualifications. They will therefore be issued as non-qualified attestations, with a comparatively low level of assurance. For example, unlike a digital attestation for a driving licence, which requires a high level of assurance due to its legal and regulatory implications, these attestations would have a level of assurance more comparable to that of digital attestations used for services such as cinema tickets or gym memberships. There are no individual approval processes or ongoing management duties for these providers. Consequently, associated costs would be limited to fixed IT infrastructure rather than variable administrative casework

On the one-off side, publishing an open, non-qualified EAA schema together with self-service adoption guidance is estimated at €400,000, reflecting the work of designing and releasing a generic schema with no accreditation logic attached. A further €150,000 one-off cost covers the production of generic guidance and helpdesk material aimed specifically at non-accredited issuers, to support voluntary adoption. On the recurring side, maintaining and versioning the open schema as EAA/European Learning Model (ELM) standards evolve is estimated at €150,000 annually, while ongoing helpdesk support for voluntary adopters is estimated at €60,000 annually. This support is deliberately light-touch, since there is no registration process or per-organisation casework to administer, in contrast to the accreditation-based costs incurred for the issuance of qualifications. These figures are Commission estimates based on the scale of comparable one-off publication and helpdesk exercises, as well as on the European Commission’s experience in developing application profiles in the European Learning Model (ELM) to address different use cases and stakeholder needs.

Table 7: Cost for the EC to support non-formal micro-credential issuers

Figures are expressed in millions of euros.

6.1.1.2Member States

Cost of having a national registry of qualifications, accreditation and awarding bodies and to connect it to Europass

One of the main efforts under this initiative will be for MS to connect (one-off) and maintain (recurrent) the databases containing information on qualifications, awarding bodies, and accreditation. As explained in the description of the policy options, in many MS this information would already be available, while in others, MS would need to either digitalise or collect it. For these calculations, the baseline considers differences in MS readiness 141 .

Under PO2, these databases will need to contain information not only on new qualifications, but also on those awarded over the past ten years. This is why the one-off costs for PO2 are expected to be higher than for PO1 and PO3.

The ten-year cut-off is anchored to 2017, the year in which the EQF Recommendation was revised and by which most MS had established or referenced their national qualifications frameworks (NQFs) to the EQF. By the end of 2017, 34 of the then 39 participating European countries had referenced their NQFs to the EQF, with the EQF acting as a catalyst for the development of NQFs across Europe. Going further back would mean reviewing qualifications from before these frameworks existed, requiring substantially more effort for comparatively little gain. Conversely, a shorter cut-off would not proportionally reduce MS' workload, since the core verification and mapping tasks remain largely fixed regardless of the period covered. Ten years therefore offers a proportionate, defensible balance between comprehensiveness and administrative burden.

Once qualifications are included in the national registry of qualifications, they become part of a trust framework that enables both the automatic issuance of a digital attestation and the automatic verification of a digital attestation within that trust framework. Such attestations can then be treated in the same way as the newly awarded digital qualification attestations, with minimal marginal unit costs for the issuance and verification of these digital attestations (set at €3.5 and €3 respectively per attestation). These minimal costs reflect the fact that, once requested, the issuance and verification of qualifications within the trust framework should require no further human interaction: the process is fully automated from that point onward, meaning the marginal unit cost is low.

Therefore, the 10-year backlog included in PO2 can be considered an initial investment that will pay off, since it will be far cheaper to automatically issue digital attestations for qualifications already included in the databases than to issue them for past qualifications, where the administration would need to manually collect all the necessary information each time a citizen requests one for working across borders. It will also be cheaper for employers to verify these qualifications that belong to the 10 years backlog of PO2 than the historical ones (details are presented below, in the direct benefits section).

Table 8: Cost for MS to have, connect and maintain national registries of qualifications, awarding bodies and accreditation

Figures are expressed in millions of euros.

A sensitivity analysis can be found below to show how this extra effort of creating a 10-year backlog would pay off (further details can be found in Annex 4.1.3). With the 10-year backlog, an estimated share of past qualifications benefits from the cheaper unit cost of issuance and verification. Without the 10-year backlog, however, all past qualifications are issued and verified at the higher unit cost.

Table 9: Sensitivity for the 10 years backlog

Figures are expressed in millions of euros.

Cost of providing a verification software

Reading digital attestations requires dedicated verification software, and the cost structure differs sharply by policy option. Under PO1 and PO2, which rely on the EUDI Wallet, labour market actors are free to develop their own verification software, but they can always use the version MS must make available to any third party.

Therefore, MS, must localise and integrate the EU reference verifier (built centrally by the European Commission) into their own national wallet trust infrastructure, at an estimated one-off cost of €280,000 per Member State, plus €70,000 annually to host, update, and support it thereafter. This is a considerably lighter lift than building verifier software from scratch, but still a new requirement for all MS under SPI, regardless of their existing digital readiness.

Under PO3, by contrast, labour market actors simply use the existing Europass Viewer 142 to read qualifications stored in people's Europass wallets, and since the underlying Europass EDC verifier is already hosted and centrally operated at EU level, no Member State needs to provide extra verification software or build separate national infrastructure, so this cost is set at zero.

Table 10: Cost for MS to provide a verification software

Figures are expressed in millions of euros.

Cost of providing an issuing infrastructure for qualifications

For the calculation of the costs associated with the issuance infrastructure for new qualifications, the model used is relatively complex (see Annex 4.1 for further details) and distinguishes between three types of actors, as they are not interchangeable and are affected differently across the policy options:

·Education and training institutions/issuers of qualifications are the entities that actually deliver learning and award qualifications (e.g. a university or training centre). The calculations consider the different number of institutions per MS as presented in the baseline (see annex 4.1. for further information).

·Awarding bodies are the entities formally accredited to award a given qualification. In many cases this is the same organisation as the education and training provider, but not always (for example, a national exam board may award a qualification on behalf of multiple training providers). The model that is used for calculating these costs considers these differences across MS (see Annex 4.1).

·Issuers of digital attestations only exists in the context of the EUDI Wallet. This is the entity that digitally signs and issues the attestation into the wallet. Under PO1 and PO2, this role is separate from the awarding body; under PO3, it is not, the awarding body performs both roles itself.

This last distinction is the main driver of cost differences between the policy options and is explained below.

Under PO1 and PO2, issuance is centralised through national or sub-national Qualified Trust Service Providers (QTSPs) or public-authority platforms. Awarding bodies do not hold their own signing capability; instead, a delegated issuer signs digital attestations on their behalf, under a formal mandate. This reflects a real regulatory barrier: becoming a QTSP, or an equivalent public-body electronic attestation of attributes (PuB-EAA) issuer, involves requirements that most awarding bodies would not meet or want to meet on their own. As a result, under PO1 and PO2 a separate issuer infrastructure needs to be built and maintained.

Under PO3, issuance instead relies on the existing Europass European Digital Credentials (EDC) ecosystem. This ecosystem is gated by the same trust framework as under PO1 and PO2, an accreditation database and a register of authorised awarding bodies and is granted legal equivalence to EUDI-native attestations. However, because EDC does not carry the same QTSP/public-authority barrier, issuance under PO3 is distributed: each authorised awarding body acquires and holds its own e-seal and issues attestations directly, without needing a separate delegated issuer. This extends EDC's existing "any institution with a seal" model to a gated, accredited population, and removes the need to build a national issuer platform.

Several one-off costs apply regardless of policy option. At the national level, a Member State designing a fully bespoke attestation profile faces a one-off cost of €350,000, or €60,000 if it instead adopts the common, harmonised SPI profile; this is a national-level cost, independent of how many institutions or awarding bodies later connect to it. At the institutional level, integrating an education or training provider's systems (mapping to SIS/ELM) costs €20,000 per institution, plus a €4,000 harmonisation delta where the institution needs to align with the common profile; this cost applies regardless of how attestations are later issued. Setting up an awarding body (covering the mandate, accreditation evidence, and trust registration) costs €25,000 per body, plus a €6,000 harmonisation delta; this reflects the cost of formally accrediting and registering an awarding body and is the same across all three policy options since they share the same underlying accreditation database.

By contrast, the one-off cost of establishing the separate "issuer" role differs sharply depending on the policy option, since this is where PO1 and PO2 diverge from PO3. Under PO1 and PO2, setting up a centralised issuer platform costs €250,000 per issuer, covering the national signing infrastructure (HSM, high availability, revocation, and onboarding), plus a €45,000 harmonisation delta for issuers that are already established; this is the direct cost of overcoming the QTSP/PuB-authority barrier described above. Under PO3, there is no separate issuer platform to build: instead, each awarding body acquires its own e-seal directly, at a one-off cost of €8,000 per body, plus a €2,000 harmonisation delta for bodies that already hold a seal (for example, existing EDC issuers). This is significantly cheaper, since the awarding body is issuing on its own behalf rather than requiring a separate issuer infrastructure to be built for it.

The annual unit costs reflect the ongoing operational expenses required to maintain the issuance infrastructure once it is in place, and here too the policy options diverge in how issuance capability is maintained. Under PO1 and PO2, maintaining the centralised issuer platform is estimated by experts to cost €60,000 per issuer annually, covering platform operations, seal renewal, and conformity reassessment, a cost that applies only under these two policy options, given their reliance on a national issuer platform. Under PO3, by contrast, there is no national platform to maintain; instead, seal maintenance takes place at the awarding-body level, at a considerably lower annual cost of €1,500 per body, reflecting the more distributed maintenance burden of this model.

Several other annual costs, however, are shared across all three policy options. Maintaining each awarding body, including mandate maintenance and updates to accreditation evidence, which is estimated by experts to cost €4,500 per body annually, regardless of policy option. Based on experts’ criteria, supporting each institution costs €3,500 annually, covering helpdesk services, connector maintenance, and retraining.

The calculations are based on the actual number of qualification issuers across the EU (32,788 - 44,354) and consider differences between MS in terms of their level of digitalisation readiness and governance structures for issuing qualifications. The number of qualifications issued is not considered in these calculations, as the individual cost of issuing digital attestations for new qualifications is not attributed to the SPI. The reason is that under the baseline scenario, MS would in any case provide an attestation of their qualification (whether in paper or digital format) to new graduates.

Table 11: Costs for MS to provide an issuing infrastructure

Figures are expressed in millions of euros.

Cost of issuing past qualifications in a digital interoperable format

Unlike new qualifications, for which the baseline already assumes that MS issue an attestation irrespective of the SPI, this impact assessment attributes the costs associated with issuing digital attestations for past qualifications when these are requested by citizens for labour mobility across the EU. The model therefore distinguishes between the one-off costs required to establish the necessary verification and issuance capability and the marginal cost of processing each individual request.

The cost estimates assume that MS having to issue digital attestations for historical qualifications obtained before the establishment of their National Qualifications Framework (NQF) would first need to put in place a dedicated archive-verification capability. Considering the experts’ criteria, a one-off cost of €150,000 per Member State is assumed to cover the establishment of the organisational and technical capacity required to locate historical records, verify their authenticity, assemble the supporting accreditation evidence and to provide the means to encode the information required to issue a trustworthy digital attestation. The one-off cost is likely to vary significantly by Member State. For example, the Netherlands has an extensive centralised register of qualifications dating back to around 1988. However, the picture is less clear for other MS, with varying degrees of centralisation and digitalisation windows. Therefore, the one-off cost estimate used in this assessment assumes the creation of procedures based on a fully paper archive-based system. This cost is common to the 3 policy options, and it does not depend on the level of readiness of the MS.

No empirical data currently exists on the marginal costs of digitalising past qualifications or on the costs of manual versus automatic issuance, as no Member State has yet implemented the automatic issuance of already awarded qualifications at scale. In the absence of such data, the parameters used in the calculations reflect plausible estimates based on expert judgement about what each process actually entails. 

Specifically, the estimates distinguish between two scenarios: a) issuing a qualification that is already part of a trust framework, where the qualification's data is structured, verified and readily accessible, allowing for a largely automated process at minimal marginal cost; and b) issuing a qualification that requires additional administrative steps to gather the necessary information  (for instance, retrieving and validating data held in non-digitised or non-standardised formats) which involves manual effort and therefore carries a higher marginal cost. The cost parameters used in the calculations were derived from this reasoning about the underlying process steps, rather than from observed cost data. 

Therefore, once the capability to issue digital attestations for historical qualifications has been established, a unit cost of €300 per qualification is assumed for the manual verification process, reflecting the effort required to retrieve archived records, validate them against paper or legacy sources where necessary, compile the evidence in line with the embedded-evidence approach used for historical qualifications, and translate the information into the required structured digital format required for issuance as a digital attestation. These figures are Commission estimates based on expert criteria, drawing upon typical costs to replace a lost paper certificate (€50 - €150) and taking into account the additional work of creating a digital attestation from it. No harmonised EU-wide process or cost benchmark currently exists for the digitisation and verification of legacy qualification records. Institutions may find ways to optimise the process, for example, by using AI or other digitalisation techniques.

However, for PO2, a distinction must be made for the subset of past qualifications falling within the 10-year backlog. Under this option, MS have to make the extra effort to bring these qualifications into the same trust framework as newly issued qualifications (this extra effort has already been quantified for PO2 under the ‘cost of having a national registry of qualifications, accreditation and awarding bodies and to connect it to Europass’). As a result, once this initial integration has been completed, the issuance of digital attestations for these recent qualifications becomes an automated process triggered upon request by the qualification holder, with only a marginal unit cost estimated at €3.5 per qualification. This marginal unit cost is based on an estimate of the fees that a QTSP may charge per attestation issuance, although it is recognised that QTSP charging models are not available at the time of writing. In reality, the unit costs may vary by QTSP, volume and time. In addition, the unit costs could be lower for attestations issued by public authorities. This is the main cost difference between Policy Options 1 and 2.

Since the EU has no direct data on the vintage of qualifications used for labour mobility across MS, the model estimates their distribution using a proxy based on the age profile of EU movers, as younger movers are more likely to hold recently acquired qualifications. The fact that 15–34-year-olds made up around 36% of EU movers in 2024 143 provides a starting point, leading to an assumption that roughly 40% of qualifications presented by movers are either newly issued or issued within the previous 10 years, with the remainder classified as older historical qualifications. This distribution is then projected forward over the 10-year appraisal period, with the share of newly issued qualifications growing as new cohorts accumulate, historical qualifications declining as older cohorts are replaced, and the 10-year backlog category remaining broadly stable, since these qualifications' holders are expected to stay active in the labour market throughout the period 144 .

By contrast, the difference between Policy Options 1 and 3 does not arise from the issuance process itself, but from the higher uptake of the EU Digital Identity Wallet under Policy Option 1, which increases the number of requests for historical qualifications.

The calculations are based on the estimated annual range of EU movers whose qualifications are expected to be verified (220,110–277,530) and on the projected progressive uptake of each of the two wallets. For this reason, the recurrent costs cannot be presented as a simple annual figure. They assume that all mobile citizens who possess a wallet and need to present a historical qualification in another EU MS will actively request its issuance as a digital attestation. The model also incorporates the projected distribution of qualification vintages over the 10-year period, distinguishing between recent (those within the 10 years backlog 145 ) and older qualifications in accordance with the assumptions set out in Annex 4.

Table 12: Cost for MS to issue past qualifications

Figures are expressed in millions of euros.

6.1.1.3Issuers of non-formal micro-credentials

Cost of issuing digital attestations for micro-credentials

Under Policy Options 1 and 3, non-NQF micro-credential issuers would also be required to issue verifiable and interoperable digital attestations for their skills documents and would therefore incur the associated implementation costs. As discussed in the baseline, the number of affected issuers cannot be determined precisely; a lower-bound estimate of 45,000 non-NQF micro-credential providers across the EU-27 is therefore used. Given the lack of sufficiently robust data, the model does not attempt to disaggregate this population by Member State. Each provider is assumed to incur a one-off capability cost of €5,000 to acquire a seal and establish the technical capacity to issue digital attestations according to expert criteria, resulting in an estimated total one-off cost of €225 million. In addition, each provider is assumed to bear an annual maintenance cost of €800, corresponding to an estimated €36 million per year across the EU. These costs are borne entirely by the issuing organisations rather than by public authorities. The model further assumes full adoption of SPI-compatible, harmonised issuance, reflecting the legal obligation under Policy Options 1 and 3. In practice, however, such an obligation would be difficult to enforce given the nature of the non-formal education and training sector, as providers could choose not to issue micro-credentials following the completion of training rather than comply with the new requirements. This uncertainty should also be considered alongside the fact that it is not possible to establish an upper bound for the number of organisations affected by this obligation. In principle, the obligation could extend to any organisation that issues a micro-credential following the provision of a short course or other learning activity in a non-formal learning setting.

Table 13: Cost for issuers of non-NQF micro-credentials to issue digital attestations

Figures are expressed in millions of euros.

6.1.2.Direct benefits

Three main stakeholder groups will directly benefit from any of the three policy options under Action 1 of the Skills Portability initiative:

·Employers (and other labour market actors who check qualifications): It will be cheaper for them to assess the meaning and authenticity of a qualification issued in another Member State.

·Workers: It will be cheaper for them to present official proof of their qualification to an employer in another Member State.

·Issuers of qualifications: They will be contacted less often by employers and other labour market actors seeking to verify the authenticity of a qualification they have issued.

In addition, this section discusses, without quantifying, two further areas where the initiative is expected to have considerable unintended positive impacts: national labour markets and access to further education and training.

6.1.2.1Employers

Cost savings for assessing qualifications issued in another Member State

Leaving aside the regulated access to certain professions, employers have full discretion to decide how much weight to give a qualification presented by an applicant, whether to consider them eligible for a vacancy, or to place them in a wage category linked to their qualification level.

Like any economic actor, however, employers benefit from reliable information to make informed decisions and reduce risk and uncertainty. When employers lack the understanding of level and content or the capacity to verify the authenticity of a qualification issued in another Member State, that qualification's signalling value in the labour market is reduced. This creates an incentive for both workers and employers to spend time and money obtaining a comparability statement, even when they are not required to.

Some employers may want greater reassurance and spend more time on this or ask the applicant for a comparability statement issued by an assessment body (a trusted third party to which they outsource the assessment). Others may accept the qualification at face value. Employers with less HR capacity (presumably SMEs) may have less capacity to carry out this assessment, even though their understanding of the qualification would be equally valuable to them. Similarly, employers facing greater labour shortages, regardless of size, may be under pressure to fill vacancies quickly and have less time to spend on assessment. AI is expected to facilitate this in-house assessment. However, the reliability of information available online cannot be guaranteed unless MS are obliged to share official, standardised information on their qualifications. Also, the fact that the qualification is genuine and linked to the holder cannot be easily established with AI.

Given the uncertainty and variability in employers' behaviour regarding the effort spent understanding and comparing a qualification from another Member State, this impact assessment does not quantify these benefits for employers. However, under all three policy options, all employers and labour market actors, including SMEs, will benefit from access to reliable and comparable information on qualifications across the EU, displayed in a user-friendly manner through the Europass comparison tool. For this cost saving quantification exercise, the focus is placed on the time spent by employers verifying the authenticity of a qualification. The model assumes in the baseline an average of 2 hours (i.e. 0.25 staff-days) needed to check the authenticity of a paper qualification from another EU Member State at an average day rate of €411.68 146 , which translates into a paper-based cross-border employer assessment cost of €103 per qualification. This is the baseline rate, held flat throughout, regardless of what any MS builds independently. Under SPI, this rate continues to apply to whichever share of movers has not adopted the wallet. Again, in the dynamic baseline, it is not possible to make a precise quantitative estimation of how employers go about checking the authenticity of a qualification. However, the uncertainty around these figures is not necessarily a major concern from a cost-benefit perspective. Employers who were already spending time and money checking the authenticity of qualifications will, under any of the 3 policy options, face only marginal residual costs (not created by this initiative but rather remaining despite of it), so net benefits are guaranteed. Employers who previously could not afford these checks or waiting for a comparability statement and were pushed to accept or reject qualifications without verifying them, will now benefit from automatic verification of qualifications at marginal cost if they wish so. It could be argued that this will be of particular help to SMEs, which, having fewer human resources at their disposal, will benefit on an equal footing from automatically verifiable digital credentials at marginal cost.

Under Policy Options 1 and 2, the model estimates that employers will still face a marginal residual cost of €3 per verification (the verification is fully automatic, though there is an expectation that the employer may wish to view the information), which remains flat throughout the period. This applies only to the share of EU movers with "new" qualifications, or, in the case of Policy Option 2, qualifications from the past 10 years. However, "historical qualifications" will still carry a cost of €20, since they contain embedded evidence that must be checked, so the verification is not that automatic.

Under Policy Option 3, the model estimates that employers will face a cost of €10 per verification of the new digital attestations. This is higher than under PO1 and PO2 due to the additional checks still required under the Europass wallet, such as identity verification. However, for the share of historical qualifications converted into digital attestations, the remaining verification cost for employers is still €20.Each of the options considers the range of annual EU movers for whom their qualification will have a use in the labour market (220,110 –277,530), and the progressive uptake of the wallets over the 10-year period. The vintage distribution of qualifications used for labour mobility across MS is apportioned as explained in the section above and detailed in Annex 4. In this exercise of quantification, the calculations for the baseline scenario yield total costs to employers of €226.7–285.9 million over 10 years.

The calculations of benefits (cost savings) for employers are deliberately conservative, as they assume that each jobseeker holds only one qualification, and that an employer needs to check the authenticity of only one qualification per vacancy in which a qualification is listed as a requirement. There is no official data 147 on how many applications a jobseeker submits before securing a job, nor on how many applications an employer receives or reviews per vacancy. It is nonetheless reasonable to guess that the actual figure is higher than one, meaning the true benefits for employers are likely correspondingly larger than estimated here.

Table 14: Cost savings for employers to assess qualifications

Figures are expressed in millions of euros. Costs savings start in year 4. Present value 2026-2040.

Finally, it is also relevant to discuss here the potential cost savings for other labour market actors that also check the meaning and the authenticity of qualifications issued in another Member State: competent authorities in charge of issuing recognition decisions to access a regulated profession and assessment bodies that conduct thorough comparability statements. Regardless of the evolution of their volume of work, they all would benefit from the availability of official and comparable information on qualifications from another Member State and from automatically verifiable digital attestations for qualifications.

6.1.2.2Workers

Costs savings due to fewer and cheaper comparability statements

Either to ensure that their qualifications have signalling value in another Member State, or because a potential employer has requested it, some workers seek to obtain a comparability statement issued by an assessment body. The annual cost of issuing comparability statements in the baseline is estimated by combining the expected annual volume of requests (90,000) with the average cost of processing each request (€125–€375). On this basis, the total annual cost is estimated to range from €11.3 million to €33.8 million.

Under all three policy options, reductions are assumed both in the number of comparability statements requested and in the cost of obtaining them. Based on SME Panel results, 62% of employers request comparability statements primarily to: (i) better understand learning outcomes in relation to domestic qualifications, (ii) verify qualification authenticity, (iii) determine the appropriate wage or pay category, and (iv) recognise and value employees' qualifications. Since digital attestations and readily available official information on qualifications would address these needs directly, it is assumed that, under full adoption, these employers would no longer require a separate comparability assessment. This potential reduction is reflected in a 62% decrease in demand under PO1. A slightly lower reduction is assumed for PO2 (60%), reflecting its more limited coverage, which nonetheless retains the qualifications most relevant to the labour market. PO3, meanwhile, is assumed to reduce demand by 45%, reflecting the comparatively weaker trust framework associated with the Europass wallet relative to the EU Digital Identity Wallet.

The assumed reduction in the cost of comparability statements is more conservative: 20% under PO1 and PO2, and 15% under PO3. These estimates are based on stakeholder feedback indicating that digitalisation is likely to streamline assessment procedures and reduce administrative effort. As no robust evidence is available to quantify this effect, a cautious reduction factor is applied, with a lower estimate for PO3 for the reasons outlined above.

The projected uptake of the different wallets over 10 years is also factored into the calculations to present the cumulative benefits.

Table 15. Cost savings for workers in comparability statements

Figures are expressed in millions of euros. Costs savings start in year 4. Present value 2026-2040.

This cost saving for workers could potentially overlap with the cost saving for employers presented above. However, since the benefits for employers are estimated very conservatively, it remains relevant to present this saving separately, as it is likely to capture value not already reflected in the employer-side estimate.

Finally, there is another direct economic benefit for workers that could be considered in this impact assessment, relating to comparability statements: the time it takes to obtain one. However, since it is difficult to prove that this time would directly translate into earlier access to a job in another Member State, it is preferable not to monetise it, and instead to mention it only as a qualitative consideration.

6.1.2.3Issuers of qualifications

Cost savings due to fewer third-party requests to verify the authenticity of a qualification

In the baseline scenario, qualification issuers are frequently contacted by third parties, such as employers, recognition authorities or other organisations, to verify the authenticity of qualifications. According to the Qualification Issuers Survey, 290 out of 574 respondents (50.5%) reported having received requests from third parties to verify the authenticity of diplomas. The annual frequency of such contacts was estimated by annualising the survey response categories on contact frequency (i.e. once a week or more, several times per month, a few times per year, once a month, and less than once a year). The resulting estimate ranges from 16 to 30 contacts per year, with the lower and upper values reflecting different interpretations of the open-ended “once a week or more” category.

This cost in the baseline is estimated by combining the number of qualification issuers (32,788 - 44,354), the share of issuers expected to receive requests for information on qualifications (50.5%), the average number of requests received each year (16–30), the average time required to respond to each request (estimated at 0.25 working days), and the average daily wage in the public sector (€319). On this basis, the annual cost in the baseline is estimated to range from approximately €24.9 million to €53.6 million.

Under all policy options, digital attestations will enable the automatic verification of qualification authenticity, substantially reducing the need for third parties to contact qualification issuers directly for this purpose. For PO1 and PO2, the robustness of the EU Digital Identity Wallet trust framework is expected to ensure that only a residual 10% of verification requests for digital attestations will still require direct contact with qualification issuers. The estimated impact is the same for PO1 and PO2.

Under PO3, given that the Europass trust framework is less robust, 30% of cases are still expected to be verified by issuers of qualifications. The projected uptake of the different wallets over 10 years is also factored into the calculations to present the cumulative benefits.

Table 16: Cost saving for issuers of qualifications to verify them

Figures are expressed in millions of euros. Costs savings start in year 4. Present value 2026-2040.

On top of this, PO1 and PO3 could consider cost savings for an extra pool of issuers: issuers of non-NQF micro-credentials. Under these policy options, they would also have the obligation to issue digital attestations, and therefore they would also have the potential cost saving of not having to carry out this verification. However, it is difficult to say whether the extent to which non-NQF micro-credentials are verified is like that of qualifications.

For this quantification exercise, we take as a basis the answers to the Survey of Issuers of Qualifications. Among respondents to the survey, 69 indicated that they issue Adult and Continuing Education Certificates, Micro-credentials, or Professional Licenses/Certifications. Of these, 27 reported having been contacted to provide information about the micro-credentials they issue, corresponding to approximately 39% (27/69). Applying the same annualisation convention used for issuers of qualifications, this yields an estimated weighted average of approximately 10 contacts per year. As explained in the baseline, we take 45,000 as the bare minimum number of non-NQF micro-credentials providers and also factor in the uptake of the wallets over 10 years.

Table 17: Cost saving for issuers of non-NQF micro-credentials to verify them

Figures are expressed in millions of euros. Costs savings start in year 4. Present value 2026-2040.

These numbers are presented separately because they need to be interpreted with more caution. It could reasonably be argued that employers are less likely to verify the authenticity of non-NQF micro-credentials with issuers (e.g. a certificate for an upskilling course issued by a non-profit organisation) than they would for a formal qualification (e.g. a bachelor’s degree issued by a university).

6.1.2.4Unintended positive impacts

This impact assessment only calculates and includes as direct benefits those that are related to the free movement of workers. However, qualifications are used for many other purposes 148 other than signalling skills when applying for jobs in another MS. Therefore, coordinated digitalisation under the SPI is expected to generate significant unintended positive impacts in other areas.

National labour markets, including national workers holding a qualification from another EU country. Verifiable digital credentials will make verification and assessment processes cheaper for employers, including for purely domestic qualifications, not only cross-border ones. This spillover would not materialise in MS that had already developed their own national digital credential systems for qualifications, since they would already capture these efficiency gains. However, by accelerating and effectively mandating digitalisation, the SPI ensures that MS which would otherwise have continued to rely on paper-based or fragmented systems also benefit from these efficiency gains, extending them beyond the cross-border use case that motivates this initiative. In terms of magnitude, this would affect all the workers that apply for jobs in a qualification-relevant position and that are not mobile workers. Within this group, there is also the specific case of national workers who hold qualifications issued in another Member State. These are not considered EU mobile workers, but insofar as they were EU mobile students, they will now benefit from the Skills Portability Initiative to use their qualifications in their own Member State. To get an idea of the potential magnitude of this case, according to Eurostat 149 , in 2024 there were 413,700 tertiary students from abroad who graduated in the EU. These are degree-mobile graduates: students who completed their entire qualification in a Member State other than the one where they finished secondary education. Around 43% of students from abroad studying in the EU come from elsewhere in Europe, suggesting that a substantial share of these full-degree graduates are EU nationals who, after completing their studies abroad, may potentially return to their home Member State to enter the labour market with a qualification obtained in another MS.

Access to further education and training. Interoperable and verifiable digital credentials will also facilitate access to further education and training, both in a national context and in another Member State. Many comparability statements are currently requested precisely for this purpose 150 , to support applications for further studies in another Member State, and a trusted, easily verifiable digital credential would streamline this process, reducing reliance on the same cumbersome, paper-based comparability procedures that currently affect labour mobility. To get an idea of the potential magnitude of this area, according to Eurostat, there were 19.1 million tertiary education students in the EU in 2024, and of the 1.83 million students from abroad undertaking tertiary level studies across the EU that same year, 43% came from within Europe 151 . This gives a sense of the scale of students in the EU that could use their digital attestations for qualifications to access further learning and the intra-European student mobility that could benefit from smoother, digitally verifiable recognition of qualifications.

6.1.3.Overview of cost and benefits

Table 18: Summary overview of total costs and benefits (present value, 2026-2040, in EURO million, the benefits start to occur from year 4, after transition period)

6.1.4.Indirect benefits

All POs are expected to bring some indirect benefits, which are potentially significant but cannot be estimated reliably given the uncertainties concerning the exact extent to which portability of qualifications impacts labour market outcomes.

Levels of overqualification are higher among EU citizens working in another Member State and overqualification results in a wage penalty. Overqualification can have different causes (e.g. insufficient knowledge of the language of the host country, or wage arbitrage, where workers accept a lower-skilled position because the absolute wage still exceeds what they would earn in their home Member State). In cases where currently the relatively lower signalling value of qualifications from another MS leads to lack of or only partial acceptance of these qualifications, the POs would improve the opportunities for EU mobile workers to make a fuller use of their qualifications. This could contribute to increased wages for those workers.

The POs could also have some indirect impacts on productivity and labour market participation. The literature on labour market mismatches, of which overqualification is a specific case, assumes that reducing mismatches stemming from misunderstandings of information about skills or qualifications could increase overall productivity by about 5% on average, and by more than 8% in some countries. 152 In terms of labour market participation, workers are presumed to actively search for employment (and find it) when their perceived chances of securing a well-paid job increase. 153 Addressing the information problem of foreign qualifications and credentials within EU could increase both the chances of finding a job abroad and of finding a well-paid job. This in turn could contribute to a (slight) increase in the number of active people in the labour force.

The effects are expected to be similar across the three POs. Given that the labour market value of micro-credentials is lower, these impacts under PO1 and PO3 are not expected to be significantly higher. Similarly, the automatic inclusion of qualifications from the previous 10 years in PO2 would mean for workers that they get their digital qualifications quicker compared to PO1 and PO3 but eventually those workers would also benefit from the digital attestations under PO1 and PO3, meaning that high level indirect benefits are likely to be similar.

Finally, ensuring a standardised approach to digital qualifications and embedding legal, and technical interoperability in the early stages of MS’ digitalisation efforts can potentially lead to costs savings in the future and support effective investment of public funds. While these benefits cannot be reliably established, they would likely be more pronounced in PO1 and PO2 given that in these POs use is made of a more general framework of the EUDI Wallet rather than investing in a system dedicated only to qualifications.

6.1.5.Indirect costs

No indirect costs have been identified for the POs.

6.1.6.Functioning of the internal market 

The POs are expected to contribute positively to internal market functioning and EU competitiveness by reducing information asymmetries and administrative barriers around qualifications, lowering recruitment uncertainty and shortening hiring timelines. While mobility decisions are driven by a wide range of non-economic factors, family ties, language barriers, housing and personal preferences, facilitation of cross-border hiring can have some effect on skills mismatches and improve labour allocation, particularly in tight labour markets and border regions.

SMEs are expected to benefit relatively most from the initiative. Currently, SMEs face higher relative costs when assessing non-national credentials due to limited HR capacity and expertise. The availability of information on qualifications including fully verifiable digital credentials specifying level and content of qualifications would substantially reduce the time and resources required for qualification verification, lowering recruitment costs and barriers to hiring mobile workers. This is particularly relevant for SMEs operating in sectors with high mobility needs or short recruitment cycles, where the ability to assess and trust non-national qualifications quickly can be decisive.

While PO1 and 3 offer the broadest credential coverage and would in principle maximise the pool of verifiable credentials, their inclusion of credentials outside NQFs raises quality assurance concerns that may undermine employer trust, particularly among SMEs with limited capacity to assess credential reliability. PO2, by restricting coverage to qualifications included in NQFs while providing retroactive digitalisation for the cohort that is most likely to be mobile, strikes a more effective balance between coverage and credibility, and is therefore expected to deliver the most tangible and reliable benefits for SMEs. It is also worth stressing that employers can rely on MS-provided verifier software, particularly useful in the case of SMEs, so that they need not bear any cost of integrating verification software into their HR or recruitment procedures.

Beyond internal market effects, the initiative has the potential to strengthen EU competitiveness at the global level. By setting up a harmonised framework for the digital issuance and verification of qualifications, built around the EUDI Wallet and common data standards for POs 1 and 2, and based on tools facilitating comparability of qualifications, the EU could position itself as a standard-setter in the emerging global infrastructure for skills and credential portability. As third countries and international organisations develop their own digital credential systems, EU standards are likely to serve as a reference model, creating a de facto basis for comparability and interoperability at the international level. This dynamic is directly relevant to Action 3 of the SPI, which covers third-country nationals.  154

6.2.Social impacts 

The proposed policy options are expected to positively impact labour mobility, employment, and working conditions for EU mobile workers, though effects on employment and mobility levels may remain modest as explained in the section above. Primary benefits will relate to working conditions and job quality, with impact expected to grow as labour market actors adapt to new procedures and systems and awareness-raising measures build trust and ensure uptake.

All options improve on the baseline by facilitating access to reliable and comparable information on qualifications issued across the MS and allowing labour market actors to benefit from interoperable digital credentials for qualifications displaying a comparable type of information. This would improve employer job matching, including wage and task allocation, and contribute to reducing overqualification 155 . All options are also expected to improve social inclusion in relation to the baseline through cost and time savings for EU mobile workers. However, barriers such as country-of-origin bias may persist, limiting these overall effects.

PO1 has the broadest scope and strongest expected impact, covering all qualifications and skills documents. This supports job matching, reduces overqualification, and makes the skills of workers with non-formal or informal learning backgrounds 156 visible and portable. However, it carries significant implementation risks: treating all learning credentials equally regardless of quality assurance standards risks diluting the credibility of higher-standard credentials while burdening flexible alternative training providers with requirements not designed for them in a context of uncertainty in the overall number of providers 157 .

PO2 strikes a balance 158 by restricting the scope of digitalisation and information availability to qualifications and micro-credentials included in the NQFs, which guarantee a baseline standard regardless of whether they come from formal institutions, non-formal providers, or skills validation processes. This option covers past qualifications without delay for the purpose of employment in another Member State for the ten most recent years and beyond on request, within a reasonable timeframe and for access to employment in another MS, ensuring the broadest possible reach in comparison to the baseline while maintaining quality assurance

PO34 matches the level of ambition of PO1; however, the absence of identity verification in Europass would leave workers in a weaker position when seeking to prove their qualifications and skills, particularly in cases where an employer questions the authenticity or ownership of a credential.

For young people, all options are expected to bring positive outcomes. As young people enter the labour market with limited work experience, qualifications are often the primary signal of skills available to employers. Making available reliable and comparable information on skills and qualifications in the EU as well as providing for interoperable and verifiable digital attestations could therefore support better job matching and reduce the risk of underemployment at the start of a career, while limiting costs of going through qualification assessment procedures which are relatively more difficult to bear for people at the start of their career. Besides, as a non-legislative supporting measure, strengthening validation systems in line with the Council Recommendation is particularly important for individuals who mainly acquired skills through non-formal or informal learning, such as on-the-job experience or employer-provided training. By encouraging that the outputs of such validation procedures are included in NQFs, whether as qualifications or micro-credentials in line with the EU approach, the initiative supports these individuals in making their skills visible and portable across borders.

6.2.1.Impacts on Fundamental Rights

The proposed POs positively impact fundamental rights as enshrined in the Charter of Fundamental Rights of the European Union and support the European Pillar of Social Rights (EPSR) notably by:

·Enhancing labour mobility and employment rights (Articles 15 and 45 of the EU Charter) by improving availability of verifiable, secure, digitalised and interoperable information on skills and qualifications, aligning with EPSR Principle 4 (active employment support).

·Promoting equality and non-discrimination (Articles 21 and 23 of the EU charter) through providing labour market actors access to reliable and comparable information, supporting EPSR Principles 2 and 3 (gender equality and equal opportunities).

Data protection (Article 8 of the EU Charter) is safeguarded, as digital solutions (e.g. Europass and EUDI Wallet) comply with GDPR/EUDPR, with Options PO1 and PO2applying the highest standards, supporting EPSR Principle 10. No significant risks to personal data are anticipated.

6.3.Environmental impacts

The principal infrastructural development in the broader policy context for PO1 and PO2, the EUDI Wallet, will serve as the technical backbone for storing and sharing digital credentials, including qualifications. However, the EUDI Wallet is being developed independently of the SPI under the revised eIDAS Regulation, meaning its environmental footprint cannot be attributed to this initiative. While operators using the EUDI or the Europass Wallet (PO3) for digital credentials may generate some environmental impact, stakeholder consultations (including large employer associations) suggest that this shift to digital infrastructure would likely have occurred regardless of the SPI. Thus, no additional environmental burden is expected.

Indirect environmental effects may arise from economic growth driven by improved skills matching, potentially increasing resource use and emissions, though these effects are likely to align with the existing economic structure’s environmental profile, without systematically favouring more or less polluting sectors. Conversely, the SPI could support the green transition by enhancing efficiency in skills identification, helping employers, workers, and policymakers address green skills gaps more effectively. Therefore, the SPI could facilitate the deployment of workers with environmental competencies into key sectors, contributing to decarbonisation and benefiting fast-growing green sectors.

Overall, while indirect growth-related pressures may occur, the SPI’s role in improving skills alignment for sustainability, coupled with its negligible direct and infrastructural impact, suggests a modest but positive environmental contribution.

7.How do the options compare?

This section evaluates the relative performance of each policy option by assessing their effectiveness, their efficiency and their coherence with broader EU policy objectives, on the basis of criteria that can be found in the respective tables. The options are scored on a scale from '-/+' to '---/+++' based on their impact relative to the baseline. A single '-/+' indicates a minor effect, while ‘--/++’ and '---/+++' signal a moderate and significant impact respectively. ‘+/-’ means that efficiency is slightly better compared to baseline, 0 means that it is the same as in the baseline.

7.1.Effectiveness 

On effectiveness, PO2 scores highest for specific objective 1 on reliable and comparable information. (+++). It makes available more standardised and thus better comparable information on content (skills) and level of all European qualifications to labour market actors due to the mandatory updating of NQFs referenced to the EQF, and the requirement to have complete and up-to-date databases on NQF qualifications linked to the Europass platform. The data is reliable because it is based on quality-ensured information (through the NQFs, that must be regularly referenced to the EQF) and comes from official, i.e. trusted, sources.

The expected high uptake of the EUDI Wallet with a focus on the digitalisation of the most recent (-10 years) qualifications which are the ones most relevant for the labour market, allows this PO2 to provide the highest increase of standardised information. The reliability of digitalised NQF qualifications (that are quality-assured) is high under the strong trust framework that is used for this option.

In spite of the broad scope of PO1 (also skills documents), it scores only ++ because fully standardised information (based on EQF and ELM) is only provided for new qualifications. In addition, the skills documents included under PO1 have lower standards in terms of trust framework. This may erode the trust in all digitalised qualifications and skills documents, which may make the wallets (EUDI or Europass wallet respectively) a less trusted source of information.

PO3 is similar to PO1, but the expected lower uptake of the Europass wallet would lead to a moderate increase of available information, despite the broad scope (also skills documents and older qualifications). This is why this option scores lowest (+).

For objective 2 (on interoperable and verifiable digital attestations of qualifications and skills), PO2 scores also best (+++): it ensures full legal interoperability through the legal value of digital attestations even if issued in another MS, full technical interoperability thanks to a common technical standard and full semantic interoperability as it is based on a standardised data model not only for new qualifications, but also for recent qualifications (-10 years).

In addition, the strong identity verification and anti-fraud safeguards under the EUDI Wallet are decisive for its high score.

PO1 scores ++ as it ensures only partial semantic interoperability for older (including recent) qualifications and other skills documents. While it is also based on the EUDI Wallet, a part of the included documents (other skills documents) has a weaker trust framework.

PO3 scores lowest (+) because of, although otherwise similar to PO1, the Europass wallet does not allow to link the identity of the account holder, which weighs on its performance on the second criterion. In addition, its lower uptake also makes it score lower on the verifiability of digital attestations.

Table 19: Effectiveness of policy options

7.2.Efficiency 

Efficiency is evaluated in terms of the benefits of each option relative to its associated costs. As not all benefits can be expressed in monetary terms because of limitations in available data, the efficiency assessment takes into account also non-monetised benefits, such as fairer working conditions for mobile workers, easier cross-border mobility in particular for young people as well as a contribution to improved functioning of the European labour market and competitiveness, the safeguarding of fundamental rights, and spillovers into national labour markets and areas such as further learning as well as simplification.

PO2 is considered the most efficient option, with a score of + due to its ability to deliver extensive benefits in comparison to the costs involved. The monetised costs are lowest while its effectiveness in reaching the policy objectives has the highest score. In particular, PO2 combines the high benefits of a relatively fast and wide expected uptake of the EUDI wallet which influences the cost savings. Beyond the monetised benefits, PO2 has positive social impacts such as contributing to fairer working conditions for mobile workers. It is the option with the most positive effects for young people who benefit from the digitalisation of recent qualifications (-10 years) and who are the most likely to move across borders. With its focus on digitalising NQF qualifications (which are most labour market relevant), it directs the investment to the segment with the highest return, with positive spillovers on national labour markets and the area of further learning. PO2 contributes to simplification as the availability of the Europass platform centralising reliable and comparable information will reduce the need for multiple efforts at Member State level to make available and keep track of information on each other’s NQFs. Indirect benefits can also be expected: PO2 contributes positively to the functioning of the internal market and EU competitiveness: it is expected to facilitate cross-border hiring with some effect on skills mismatches and improved labour market allocation. It also safeguards fundamental rights.

PO1 reaches a score of +/- for efficiency. It combines a lower effectiveness in terms of reaching the policy objective with higher costs. The higher amounts are mainly driven by the larger scope that includes the other skills documents – a cost that is mainly placed on private providers of micro-credentials for whom this investment will not pay off as the benefits are spread over different groups. The option has similar non-monetised benefits as PO2, but without the automatic digitalisation of recent qualifications (-10 years), the positive effect on young people is weaker.

PO3 reaches the lowest score (0) as comparable costs will lead to the least effective solution with the lower take-up of the Europass wallet weighing particularly on efficiency. Non-monetised benefits are similar to PO1.

Table 20: Efficiency of policy options

7.3.Coherence

The coherence assessment is split between internal coherence, i.e. coherence with the other actions of the Skills Portability Initiative and external coherence, i.e. coherence with the broader policy context.

7.3.1.Internal coherence 

PO2 is the policy options which scores highest (+++) in terms of internal coherence with other SPI actions. By establishing common information standards and standards for digital credentials, as well as qualifications databases, the initiative reduces the cost of presenting, verifying, and recognising qualifications under the other SPI actions. In particular, using the EQF as a universal reference framework across all three actions ensures internal coherence and makes qualifications easier to compare, understand, and verify, minimising information asymmetries and fostering greater trust within the EU.

PO2 ensures the availability of interoperable and verifiable digital qualifications, which is crucial to allow for faster and less burdensome cross-border recognition processes under Action 2. The use of the EUDI wallet which provides a link to the identity of the account holder and makes use of the EUDI Wallet overall trust framework creates particularly strong synergies. The expected quick uptake of the EUDI wallet and the digitalisation of recent qualifications (-10 years) without delay (to the extent possible) will create early savings for the Competent Authorities under Action 2 on regulated professions.

PO1 also supports the other actions in similar ways, but the missing digitalisation of recent qualifications (-10 years) will create fewer immediate benefits for Action 2. The score of PO1 for internal coherence is thus ++.

PO3 scores only + because of the shortcomings already outlined under PO1 and the missing link to the identity of the Europass wallet holder, which is crucial for recognition procedures.

7.3.2.External coherence

PO2 is highly coherent (+++) with existing EU legal frameworks and policy objectives, particularly those related to the free movement of workers (including Regulation (EU) No 492/2011 on freedom of movement for workers within the Union) and the functioning of the Single Market. It is consistent with the PQD (Directive 2005/36/EC) and reinforces the EQF Recommendation objective of improving the transparency, comparability and portability of qualifications.

PO2 is also coherent with the EU's broader digitalisation agenda, including the EU Digital Decade and the Single Market Strategy. PO2 aligns well with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) the Interoperable Europe Act (Regulation (EU) 2024/903), the EUDI Wallet and the eIDAS Regulation 910/2014 for all digitally issued qualifications. Adding another set of documents into the EUDI Wallet also benefits the EUDI Wallet users. This is also coherent with the ESSPASS proposal: the use of the EUDI Wallet in both initiatives gives a single storage place for the documents mobile and cross-border workers need. PO2 also demonstrates high external coherence by combining the EUDI Wallet with the Single Digital Gateway (SDG) Regulation (Regulation 2018/1724) and the Once Only Technical System for qualifications already awarded. The new procedure under the SDG allows citizens to have access to a fully digitalised procedure to request their qualifications.

PO2 uses existing EU tools, including the Europass platform and the Open Data Portal, for the publication of accessible information on qualifications, which is strengthened in their use thanks to improved data provision by MS and a reinforced qualifications comparison tool. The digitalisation of micro-credentials in NQFs is coherent with both the EQF and micro-credentials Council Recommendations and would ensure that the data fields established in those Recommendations are properly used. PO1 achieves the same external coherence score as PO2. The coherence with the micro-credentials Recommendation is even stronger than in PO2 as all skills documents are digitalised under this PO.PO3 aligns also with the EU Digital Decade by digitalising qualifications, it conforms with the GDPR requirements, and like PO1 and PO2 gives legal value to digital credentials. However, it does not align with the EUDI Wallet and therefore does not provide any link to the identity of the account holder and does not benefit from the EUDI Wallet’s overall trust framework, established under the eIDAS Regulation. It is also incoherent with the EUDI Wallet, which will be made available by all MS to their citizens, since it will create a parallel system of wallets and trust services. PO3 builds on the Europass infrastructure in line with Decision (EU) 2018/646, ensuring continuity with current practices and growing familiarity for employers and workers alike and coherent with the Europass platform at large as a one-stop-shop for skills and career management. PO3 therefore scores ++ for external coherence. The coherence with the micro-credentials Recommendation is the same as PO1 as all skills documents are digitalised under this PO. PO3 therefore scores ++ for external coherence.

Table 17: Coherence of policy options

7.4.Overall comparison of Policy Options

Table 18: Comparison of the POs across all assessment criteria relative to the baseline 159

The policy options are also assessed against the principles of proportionality and subsidiarity as required under Article 5 of the Treaty on European Union. PO 2 is the most proportional as it limits the scope of qualifications covered by digitalisation to those most relevant for the labour market and therefore striking the best balance between benefits and costs. For young people, since they are more mobile than other age groups (those aged 15-34 years constituted 36% of the entire EU mover population in 2024), future and recent issued qualifications (up to 10 years in the past) would be largely covered. 160 PO1 raises significant proportionality concerns due to its broad scope and the consequent high burden of digitalising all existing NQF qualifications and skills’ documents, and all past qualifications on demand, without distinguishing between NQF and non-NQF qualifications, which may go beyond what is necessary. PO3, while similarly broad in scope, is considered a bit more proportional than PO1 as it leverages the existing Europass framework.

On subsidiarity, all options address an inherently cross-border problem that MS cannot resolve alone and therefore justify EU-level action. Similarly, all options build on an interoperable EU-wide digital infrastructure for qualifications, which cannot be achieved by MS acting individually. EU-level coordination, standardisation and funding support are therefore necessary and create clear added value for cross-border labour mobility. 

8.Preferred Option

The impact assessment resulted in PO2 as the preferred way forward to achieve the specific objectives 1 and 2 in the most effective, efficient and coherent way.

Thanks to the digital qualification attestations issued in the EUDI Wallets and the reinforced comparison tool in Europass, employers and workers will have free and easy access to information on the level and content of qualifications issued in the other MS. The information will be fully reliable, as the PO focuses on qualifications included in the MS NQF, which are quality assured and the content of the digital attestations and the information in the comparison tool will be based solely on official administrative data. It will be comparable – both digital attestations and the comparison tool will include up to date EQF level references, and the presentation of the information will be standardised. The information will be instantly verifiable for new qualifications and facilitated for older ones – both in terms of authenticity of the qualification and its issuer and in terms of the link to the holder’s identity. The solution is fully interoperable thanks to common legal, technical and semantic standards.

The preferred form of legal act for the PO is a regulation as an instrument which provides advantage of establishing a uniform set of rules that are directly applicable across the Union. Being directly applicable and setting minimal requirements without further need of any transposition by MS, regulation will contribute to a quicker unification. It will ensure that the envisaged tools to improve the availability of reliable, comparable and interoperable digitalised information on skills are based on consistent data from the MS and meet the same technical standards and specifications so that they can be trusted as authentic and quality approved. As a directly applicable legal instrument, the regulation will also be easier and to implement.

Setting up a comprehensive and interoperable system of digital attestations of qualification comes at a cost to national administrations and education and training providers. The preferred option keeps those costs to a minimum by firstly, choosing EUDI Wallet as a technical solution where a significant part of the investment has already been decided to make irrespective of this initiative, and secondly by limiting the scope of the initiative to NQF qualifications where most of the information necessary for the establishment of the required trust framework is already at the disposal of the MS. It also strikes a balance between covering a larger proportion of the workforce thanks to automatic issuance of some historic qualifications and making it practically feasible and cost-effective. Limiting the automatic issuance to the last 10 years means that MS can to a significant degree rely on already existing databases and ensuring that the attestations are provided solely for the purpose of labour mobility and giving the possibility to provide a more limited set of information further addresses potential challenges of digitalising past qualifications.

Overall, the proposed solution will be a significant step forward in how qualifications from other MS can be used in practice in the single market. While not touching on MS competence in organising their education and training systems, the PO builds on policies and tools developed so far and brings them a step forward, towards a fully connected system whereby qualifications obtained in other Member State are easily understood and verified and thus have a signalling value which is closer to national qualifications.

This will have direct benefits for workers and employers, who will save time and money on costly processes of verifying qualifications and comparing them to national standards. The availability of digital attestations will be relevant for workers in regulated and non-regulated professions. When it comes to regulated professions, it is a precondition for the modernised and simplified system of formal recognition put forward in Action 2 of the SPI.

Broader positive effects of the PO are expected, which could not be monetised in a robust manner such as effects on employability or overqualification levels. A significant positive spillover effect is expected on portability of qualifications in national labour markets and in the context of learning mobility, potentially saving time and costs to a much higher number of citizens. In addition, setting common EU standards for digitalisation of qualification at this stage, where national investments are starting but the national systems have not yet been fully established, ensures interoperability by design and prevents potentially higher costs in the future where divergent national approaches would further complicate the understanding of qualifications from other MS for employers, and where eventually a variety of fully fledged national systems would need to be adjusted to be interoperable.

8.1.Summary of cost and benefits for the preferred Policy Option

A breakdown of the estimated costs and benefits of the Preferred Option is provided in Annex 3, which presents each impact by stakeholder group (workers, employers and public authorities).

8.2.Application of the ‘one in, one out’ approach 

There are no expected administrative costs for citizens and businesses arising from the initiative.  

9.How will actual impacts be monitored and evaluated?

The Commission would establish a dedicated monitoring framework covering the Operational Objectives set out below and the corresponding output, result and impact indicators. Together, these indicators would support both the monitoring of implementation and the future evaluation of the initiative.

A report on the progress of the initiative would be envisaged five years after the date of entry into application of the legislative act. In addition, an evaluation will be foreseen in line with Better Regulation requirements.

To facilitate monitoring and evaluation, the Specific Objectives are translated into Operational Objectives (OO):

Specific Objective 1: By the end of the transition period, labour market actors have access to reliable and comparable information on skills and qualifications issued in the EU.

Corresponding Operational Objectives:

·OO1: By the end of the transition period, all MS have their NQF databases fully connected to Europass with standardised metadata

·OO2: By the end of the transition period, all MS submit up to date EQF referencing reports to guarantee the Europass comparison tool provides accurate, up-to-date equivalence information.

Specific Objective 2: By the end of the transition period, labour market actors in the EU can benefit from interoperable and verifiable digital attestations of qualifications and skills.

Corresponding Operational Objectives:

·OO3: By the end of the transition period, all MS issue all new qualifications (EQF levels 2–8) digitally via the EUDI Wallet

·OO4: By the end of the transition period, all MS can digitise and issue qualifications from the past 10 years via the EUDI Wallet automatically for cross border employment

·OO5: By the end of the transition period, all MS can digitalise and issue qualifications awarded between the past 10 and 45 years into the EUDI Wallet within 14 days of request (e.g., for professional recognition procedures or for other employment in another MS purposes)

·OO6: By the end of the transition period, digital qualifications issued through the EUDI Wallet can be automatically verified across MS.

·OO7: By the end of the transition period, all MS recognise the legal value EUDI Wallet-issued digital qualifications.

Based on the Operational Objectives, the draft monitoring framework distinguishes between output, result and impact indicators. Output indicators would monitor implementation of the operational objectives, for example the share of MS capable of issuing digital qualifications through the EUDI Wallet, or the share of MS with NQF databases connected to Europass using the agreed metadata standard. Result indicators would capture the immediate effects of the initiative on labour market actors, such as the share of newly awarded qualifications issued as digital credentials, the share of employers reporting easier access to and comparison of qualifications obtained in another Member State, or the share of mobile workers reporting that they can successfully present and use verifiable digital qualifications in another Member State. Impact indicators would assess broader labour market outcomes. As such, they are influenced by a range of external economic, labour-market and policy developments and should not be interpreted as being solely attributable to the initiative. Impact indicators include, among others, transaction costs associated with qualification portability, and employers' reporting that qualification-related barriers discourage them from recruiting candidates holding qualifications obtained in another Member State. Where possible, the framework relies on existing EU data sources and reporting mechanisms. Where suitable data are not currently available, the Commission would first assess whether existing surveys, administrative datasets or monitoring systems could be adapted before considering targeted evaluation studies or other proportionate data collection methods. The detailed draft monitoring framework, including indicators, data sources, baselines and reporting frequency, is provided in Annex 10.

Annex 1:Procedural information

1.Lead DG, Decide Planning/CWP references

DG Employment, Social Affairs and Inclusion (DG EMPL) is the lead DG.

The Skills Portability Initiative is included in the Commission Work Programme (CWP) for 2026 161 , and planned for adoption in Q3 as part of the Fair Labour Mobility Package.

2.Organisation and timing

The Call for evidence 162  providing an overview of the initiative and envisaged POs was published on 5 December 2025 on “Have Your Say” 163 and remained open for feedback until 27 February 2026 (a detailed assessment of the feedback received is provided in Annex 2).

The Impact Assessment report (IA report) is based on a number of studies and existing literature, reports, surveys and background research. A study from an external contractor was launched in October 2025 to inform the IA report.

In addition, extensive targeted consultations were conducted in the context of this initiative between October 2025 and April 2026.

Previous evaluations were also taken into account in the preparation of the IA report, in particular the European Qualifications Framework (EQF) 164 and Europass 165 evaluations published in 2024.

Inter-Service Coordination Group

The Inter-service Coordination Group (ISCG) on the Union of Skills was used by the Secretariat-General to assist in the preparation of the SPI. For the external studies supporting the IAs for the three SPI actions, specific steering groups were set up.

The representatives of the following Directorates-General participated in the ISCG work: BUDG, CNECT, COMM, EAC, ECFIN, EEAS, EMPL, ESTAT, GROW, JUST, JRC, INTPA, MOVE, NEAR, REFORM, REGIO, RTD, SANTE, TRADE, SG and the Legal Service.

One Cabinet/Services meeting was held in 2026 during the preparation stage of this IA. The representatives from the following Cabinets and Directorates-General of the Commission took part in the Cabinet/Services meetings: CAB-SÉJOURNÉ, GROW. DG EMPL has considered the comments made by Cabinets and DGs regarding the Impact Assessment.

The ISCG met 3 times to discuss the SPI, namely on 16 September 2025 (meeting on the overall Union of Skills with a dedicated point on the SPI), on 26 March 2026 (to discuss preliminary elements of the three SPI IAs) and on 27 May (to discuss the three IAs before their submission to the Regulatory Scrutiny Board).

The steering group for the external study supporting the IA on SPI Action 1 met on 13 October 2025 for the kick-off meeting, on 20 November 2025 to discuss the draft Inception report and on 19 March 2026 to discuss the draft Interim report. The draft Final report was discussed by written procedure with a deadline for comments by 3 June 2026.

Bilateral meetings with other Commission services

DG EMPL has held a number of bilateral meetings with several Commission services including DG REGIO, CNECT, GROW, ENER, LS, DIGIT. .

External meetings and consultations

The initiative touches upon different policy areas including, labour moblity, employment and recognition of qualifications related aspects. Therefore, extensive consultations were conducted with a wide range of stakeholders and experts from different backgrounds. Meetings and ad-hoc consultations with EU institutions and agencies, international organisations, MS, expert groups, high-level groups, think tanks, and civil society were organised. A full overview of the consultations conducted is available in Annex 2.

3.Consultation of the Regulatory Scrutiny Board

On 17 June 2026, DG EMPL submitted the draft IA to the Regulatory Scrutiny Board, which has examined the draft IA on 15 July 2026. The RSB delivered a negative opinion following the meeting. The revisions made to address the RSB opinion are summarised in the table below.

On 24 August 2026, the RSB delivered a positive opinion with reservations. The revisions made to address these reservations are also summarised in the table below.

Table: How RSB comments have been addressed

4.Evidence, sources and quality

An external contractor (consortium led by Ecorys) assisted DG EMPL in conducting a study to support the work on the IA report. The call for tenders for the study was launched in June 2025. Seven bids were evaluated in August-September 2025, leading to the award decision in September 2025. The kick-off meeting for the study took place on 13 October 2025 and the the draft final report was submitted on 30 April 2026. The study supporting the Impact Assessment used a comprehensive, mixed-methods evidence base combining primary and secondary data sources. It captured perspectives from all MS and key stakeholder groups identified in the consultation strategy, as well as both qualitative and quantitative evidence, allowing for robust triangulation across sources. The evidence base included:

·Relevant literature and datasets, including academic research, grey literature, policy papers, and legal sources;

·785 responses to the public consultation and 235 responses to the call for evidence, including 126 position papers;

·159 responses to a survey of SMEs;

·94 interviews, covering 140 stakeholders;

·8 focus groups, including 88 total participants;

·4 expert workshops, including 41 total participants;

·574 responses to a survey of issuers of qualifications;

·Additional consultation sources, including 8 expert meetings hosted by the Commission, 39 position papers, 16 responses to a survey of ENIC-NARIC Centres, and 21 responses to a questionnaire sent to EQF National Contact Points.

Quality assurance measures were applied throughout all stages of the study to ensure the robustness and reliability of the evidence incorporated. Broad stakeholder coverage was ensured during the consultation activities to ensure all relevant perspectives were considered, and all findings were systematically triangulated across multiple data sources to corroborate key study conclusions. Analytical and reporting outputs were subject to thorough internal review by the study team to ensure consistency, accuracy, and a strong evidence base throughout.

Annex 2:Stakeholder consultation (Synopsis report)

This annex summarises the stakeholder consultation activities undertaken to inform the IA of the Skills Portability Initiative (SPI), including the strategy adopted and results.

1.Consultation strategy

A comprehensive consultation strategy was designed to gather a broad and representative evidence base on the portability of skills and qualifications across EU countries. The evidence collected through these activities supported the problem definition and enabled the assessment of the feasibility, suitability and potential impacts of selected policy measures 166 . The consultation activities conducted are outlined in the table below.

Stakeholder perspectives make up a significant share of the study’s evidence base, so targeted measures were integrated from the outset to mitigate any potential biases or limitations. Firstly, breadth and balance of stakeholder coverage were ensured through a broad range of consultation activities, including interviews, focus groups, expert workshops, surveys, Commission-led expert meetings, a public consultation and a call for evidence. Each activity targeted distinct audiences, complementing EU- and policy-level insights with operational perspectives from stakeholders that would be directly affected by a Skills Portability Initiative. These activities collectively covered all EU MS and key stakeholder groups identified in the consultation strategy, ensuring a balanced coverage of perspectives. Additionally, data collection instruments were designed to accommodate varying levels of expertise through a mix of detailed and general questions, and respondents were assured of anonymity to reduce social desirability bias. Lastly, stakeholder views were systematically triangulated against other consultation activities, quantitative data, and reviewed literature to ensure conclusions were drawn from representative, rather than individual perspectives. Where viewpoints were representative of a specific stakeholder group, but not broadly shared, this was clearly indicated in the text.

The consultation strategy targeted a range of stakeholder groups, reflecting the cross-cutting nature of skills portability, with most stakeholder groups consulted via more than one activity (outlined in the table below).

2.Results of the consultation strategy

2.1.Public consultation

The consultation was open for 12 weeks, from 5 December 2025 to 27 February 2026, and was hosted on the Have Your Say portal in all official EU languages. The questionnaire, which comprised both closed and open-ended questions, was disseminated broadly to European Commission networks and stakeholders.

The questionnaire received a total of 785 responses. Individuals made up 61% of respondents (n=470), with the majority (n=336) being EU citizens. Amongst the 39% (n=306) of organisations responding, 10% (n=81) were public authorities, 6% (n=44) were academic or research institutions, 5% (n=43) were NGOs, 5% (n=41) were business associations, and 4% (n=29) were businesses. The most represented sectors were the public sector (24%; n=191), health (10%; n=75), and digital (10; n=75).

2.1.1.Problem definition

The most significant obstacles to skills portability cited by respondents were lengthy, complex and costly recognition procedures for regulated professions (67%, n=524) and limited employer understanding and trust in non-national qualifications (59%, n=462). Other challenges included:

·Uneven usage of EU tools: Awareness of EU transparency and recognition tools was uneven across the respondent base. The Europass Framework and EQF were each familiar to 59% (n=462) of respondents, ECTS and ESCO to 34% (n=267 and n=263, respectively), the EU Digital Identity Wallet to 24% (n=187), and the ELM to 13% (n=100). Across categories, respondents identified limited usability and insufficient coherence of existing EU instruments as the principal issues (rather than their absence).

·Underutilisation of skills validation: Only 9% (n=44) of individuals had successfully validated their skills in an EU country, although 32% (n=152) intended to do so.

·Lengthy recognition procedures: The challenges most frequently reported by employers included process duration (60%, n=15) and communication with authorities (52%, n=13). Recognition was generally pursued only where legally required, usually for regulated professions (85% of those requiring recognition) or as part of due diligence (58%).

2.1.2.Policy Options

Stakeholders expressed strong support for EU-level action. At least 90% of respondents rated all proposed objectives as areas where EU action is at least somewhat necessary. The highest priority objectives identified were:

·Ensuring that qualifications are transparent and uniformly understood across the EU (94%, n=741).

·Providing a common EU skills validation certificate (93%, n=729).

·Simplifying and modernising administrative recognition procedures (92%, n=721).

A large majority of respondents indicated they would be very or somewhat likely to use or accept EU-wide digital credentials (90%, n=714). The most frequently raised concerns about EU-level digital credentials were related to technical complexity or compatibility (59%, n=460), data privacy and security (52%, n=405), lack of legal validity across countries (51%, n=404), and potential exclusion of users with limited digital skills or internet access (51%, n=397). Respondents highlighted the importance of robust governance, inclusive design, targeted support and paper-based or hybrid alternatives to mitigate digital exclusion.

While support for EU-level action was very broad, a minority of respondents voiced concerns relating to over-reliance on digital tools, possible weakening of quality assurance for non-formal learning, and the risk of devaluing established national qualifications. Public authorities and education-related respondents generally placed greater emphasis on preserving national competences in education and on human oversight in digital infrastructure, while business and individual respondents emphasised speed, simplification and cross-border interoperability.

2.2.Call for evidence

The call for evidence ran in parallel with the public consultation (5 December 2025 to 27 February 2026). A total of 235 responses were received (excluding 22 duplicates), accompanied by 126 position papers.

Most respondents reported that the existing framework of EU-level instruments has not yet translated into an effective system for cross-border skills portability. For non-regulated professions, respondents identified the absence of agreed legal frameworks for recognition, the largely voluntary nature of EU instruments, fragmentation across digital credential providers, low implementation of and limited trust in micro-credentials, and employer uncertainty (especially among SMEs) as main challenges. Key challenges identified for regulated professions included procedural complexity and slow digitalisation, particularly for shortage professions such as healthcare and education.

Most contributions mentioned the need for EU-level coordination, although a minority (largely representing professional bodies) argued that decisions about recognition and comparability of qualifications should remain primarily at Member State level. Regarding legislative measures, some considered new legislation (such as common procedural rules, mandatory timelines and digital requirements) necessary, while others viewed new legislation as premature and warned against lowering professional standards.

Overall, there was broad consensus among respondents that investments in digital credentials, interoperability and verification systems would generate significant benefits, provided they preserve human oversight, provide non-digital alternatives, and operate under public rather than solely commercial governance. Some respondents also highlighted the risk of disproportionate implementation costs for SMEs, which they suggested could be addressed through adequate funding and implementation support.

2.3.Targeted interviews

A total of 94 semi-structured interviews were conducted between January and March 2026 with a total of 140 national, regional and EU-level stakeholders. All 27 EU MS were covered by at least two interviews, and three additional interviews were conducted at EU level. The table below provides a breakdown of interviewees by stakeholder type.

2.3.1.Problem definition

·Administrative burdens and fragmentation were identified as key obstacles. Most respondents described qualification recognition procedures as slow, fragmented and difficult to navigate, particularly where multiple authorities, certified translations or repeated documentation requests are involved, though there was variation at the Member State level. Recognition and validation authorities described an increasing volume of applications without commensurate resources.

·Limited employer trust in non-national qualifications was also identified as a key issue. Employers' organisations highlighted that many companies – particularly SMEs - lack the time, expertise or confidence to assess non-national credentials.

·Skills validation systems were described by many interviewees as underdeveloped, fragmented and unevenly known, with awareness gaps among individuals and employers identified as the main limitation.

·Regarding EU tools, interviewees largely agreed that the EQF remains the most consistently used and operationally relevant instrument, though several interviewees highlighted inconsistent referencing to the EQF as undermining credibility and called for stronger peer review or moderation.

2.3.2.Policy Options

Interviewees broadly supported EU-level action focused on simplification, coherence, transparency and trust-building, with interviewees frequently advocating for consolidation and improved implementation of existing instruments rather than the creation of new ones. Regarding legislative measures, interviewees expressed varying views. Some favoured binding EU instruments, arguing that uniform implementation requires legislative pressure. Others cautioned against new legislation, expressing that existing instruments would suffice if better implemented, or that increased legal rigidity could create new problems.

Interviewees broadly supported the development of interoperable digital credentials, with the EU Digital Identity Wallet often mentioned as a key enabling instrument. Several interviewees emphasised that this would require cryptographically verifiable, interoperable credentials linked to shared semantics. Concerns were also raised about implementation costs, particularly for smaller awarding bodies, and about the need for investment by verifiers to ensure that credentials can be processed by employers and public authorities. Trade union and civil society interviewees further emphasised that digital infrastructure should be publicly governed, accessible to users with limited digital skills, and complemented by non-digital alternatives.

Regarding expected impacts and costs, interviewees broadly anticipated positive medium- and long-term improvements to transparency, mutual trust and reduced administrative burden, while acknowledging short-term implementation costs, especially for issuers and public administrations. Several interviewees highlighted that success would be contingent on implementation-related arrangements, including capacity-building, awareness-raising, peer learning between MS and dedicated EU support.

2.4.Survey of qualification issuers

The survey of issuers of qualifications and learning credentials ran from 19 January to 3 March 2026 on the EU Survey platform and was disseminated broadly across EU networks. It gathered 574 responses from 39 countries, with the largest contingents from Poland (28%, n=161), Romania (10%, n=57), Portugal (7%, n=38), Spain (6%, n=37) and Malta (6%, n=36). No responses were received from Luxembourg, Liechtenstein, and Montenegro.

The table below provides a breakdown of survey respondents by types of issuing body.

The qualifications most frequently issued by respondents were higher education degrees (43%, n=244), adult and continuing education certificates (36%, n=205), school certificates (35%, n=202), vocational education diplomas (34%, n=197) and Diploma or Certificate Supplements (32%, n=181). Half of all respondents (50%, n=286) reported that all qualifications they issue are referenced under their NQF, with a further 23% (n=131) stating that most of them are.

2.4.1.Problem definition

Respondents highlighted several key issues. Over half of respondents agreed or strongly agreed with the following statements:

·Skills gained through work or non-formal and informal learning often go undocumented due to lack of validation pathways (63%, n=363);

·Current digital credential systems remain fragmented (61%, n=354);

·Differences in national systems make qualifications hard to compare (59%, n=336);

·The lack of a common legal framework limits the cross-border acceptance of micro-credentials (56%, n=323).

The survey also indicated that paper-based issuance remains dominant, with 82% (n=468) of respondents issuing paper certificates, 36% (n=206) issuing digitally signed PDFs, and 16% (n=89) issuing verifiable digital credentials in a structured, machine-readable form. The principal barriers to digitalisation identified were limited technical capacity to issue interoperable credentials (41%, n=228), lack of guidance or national support on EU-wide standards (34%, n=189), set-up and operational costs (34%, n=186) and limited awareness of EU tools (33%, n=184).

2.4.2.Policy Options

Respondents anticipated significant benefits from interoperable digital credentials, including simplification of processes (56%, n=320), improved understanding of qualifications from other European countries (44%, n=251), faster processes (43%, n=246), and reduced administrative burden in the longer term (43%, n=246).

Regarding costs, respondents reported a median current annual cost of issuing qualifications of EUR 5 000 (with a mean of EUR 123 403) and a median expected annual cost under a future digital system of EUR 10 000 (with a mean of EUR 79 276). Higher education institutions reported higher levels of digital readiness than schools, adult education centres and smaller VET providers, with respondents advocating proportionate implementation arrangements and dedicated capacity-building for smaller institutions.

2.5.Focus groups

Between February and March 2026, eight focus groups were organised, gathering a total of 88 participants. Each was conducted online, lasting approximately 2 hours, with a tailored discussion guide structured around the problem definition, costs and burdens, Policy Options and digital interoperability, supported by interactive polls.

The focus group findings pointed to a consistent set of cross-cutting themes:

·Persistent recognition barriers: Across sectoral, geographical and stakeholder perspectives, participants described recognition processes as slow, costly and administratively complex, compounded by terminological ambiguity (e.g., between 'skills' and 'competences'), regulatory divergence between MS, and structural divergences in national education systems (e.g., three-year vs. four-year degrees). Recognition delays of two to four months as foreseen in EU legislation were reported in practice to extend to several months, particularly in healthcare and education, and often become entangled with taxation and social-security regimes.

·Limited recognition of emerging and informal skills: Participants observed that workplace-based learning, informally acquired competences, and emerging skills remain systematically underrepresented in formal credentialing. Higher education qualifications were noted to have limited portability beyond higher education, and uptake of micro-credentials in professional and vocational education was described as slow.

·Fragmentation and the need for digital infrastructure: A recurring theme was the fragmentation of validation systems, tools and EU instruments, alongside a digital trust gap and significant adaptation costs for issuers transitioning to digital credentialing. Participants supported the development of a standardised, centralised digital environment, comprehensive NQF databases, inclusion in EUDI Wallet ecosystems, semantic interoperability of skills descriptions, and the consolidation of fragmented EU tools within a single portal.

·Awareness, trust and capacity-building: Limited employer understanding of non-national qualifications was raised across multiple groups, as was the broader cultural challenge of how employers’ approach entry-level recruitment and emerging qualifications. Participants emphasised that recognition or acceptance of non-national qualifications is ultimately part of a wider labour-market integration challenge in which trust-building, awareness-raising and capacity-building among all stakeholders are at least as important as technical fixes.

There were some diverging views across the focus groups. For example, the user journey for employers focus group expressed significant caution against any new EU legislation that might increase administrative burden and emphasised that education systems and qualification frameworks should remain nationally determined, favouring pragmatic, sectoral pilots over comprehensive overhaul. However, the user journey for workers and cross-border stakeholders focus groups, by contrast, argued more strongly for binding EU action to ensure consistent implementation.

2.6.Expert workshops

Four expert workshops were organised in February 2026. The workshops were conducted online (2–3 hours), based on detailed discussion guides, and combined plenary discussion with interactive polling and break-out sessions. The four workshops addressed the following dimensions:

·Skills not captured in a qualification and the use of technologies: this workshop involved 7 participants from 5 countries, representing national authorities, sectoral organisations, a higher education institution and an EU agency;

·ENIC-NARIC recognition of VET qualifications for the purpose of worker mobility: this workshop involved 12 participants from 10 countries, mostly representing recognition authorities;

·Interoperability and infrastructure needs: this workshop involved 14 participants from 9 countries, who were predominantly researchers, VET/HE representatives, SMEs and public authorities;

·Assessing and matching skills in qualifications to job requirements: Approaches and tools used by PES / EURES and employers: this workshop involved 9 participants from 8 countries, representing public and private employment services, EURES advisers, employer organisations and HR associations.

2.6.1.Problem definition

A common topic discussed across the expert workshops was how non-formal and informal learning is used in the labour market. The principal challenges mentioned were the absence of a common language for describing skills, preference towards traditional qualifications amongst employers and institutions, awareness gaps regarding existing frameworks (ESCO, EQF, NQFs, Europass), and significant financial constraints affecting both individual access to validation and the sustainability of validation infrastructures.

Participants broadly agreed that the technology for digital credential exchange is largely available, but adoption is hindered by issues relating to harmonisation, trust and governance rather than technical limitations. These issues included the absence of common cross-border verification governance, varying interpretations of GDPR and eIDAS, and inconsistent frameworks for non-formal and informal training. Participants emphasised the need for a common trust infrastructure, shared semantics and ontologies, privacy features such as selective disclosure and verifier-side investment.

2.6.2.Policy Options

Across the workshops, participants advocated for tools to facilitate comparison, regularly updated qualification registers, improved digital access, and stronger structures for VET recognition. The credibility of EQF referencing was seen as essential, requiring stronger peer review, with IMI cited as a potentially scalable model.

On policy direction, several participants questioned whether voluntary uptake would be sufficient, suggesting that an EU-level requirement in the form of a directive or regulation might be necessary to overcome slow and uneven adoption, while others emphasised the importance of preserving prior national investments. Across the workshops, participants frequently underlined the importance of a cultural shift from a quality-control logic towards a trust-based approach, accompanied by investments in awareness campaigns and capacity-building for employers, trainers and learners.

2.7.SME panel

The SME panel was administered through the EU Survey portal in between 11 February and 1 April 2026 and gathered 159 responses from SMEs in 18 EU 171 and third countries. Respondents by enterprise size and sector were distributed as follows:

·Small enterprises constituted the largest group (31%, n=50), followed by microenterprises (30%, n=47), medium-sized enterprises (23%, n=36), large enterprises (11%, n=17) and self-employed respondents (6%, n=9).

·Manufacturing was the most represented sector (23%, n=36), followed by professional, scientific and technical activities (10%, n=16).

·Most respondents were directly involved in recruitment (58%, n=93), with a further 20% (n=31) indirectly involved in recruitment.

2.7.1.Problem definition

The principal obstacles cited were administrative and bureaucratic burdens, language barriers, difficulties verifying and comparing skills and qualifications, practical settlement barriers (work and residence permits), and costs associated with cross-border hiring. The most frequently reported challenges in assessing EU qualifications were insufficient familiarity with non-national education systems (44%, n=70), difficulty verifying authenticity (40%, n=63), language barriers (38%, n=61) and lack of clear information on the comparability of qualifications (36%, n=57).

Respondents were asked to provide cost and internal resource estimates for the processing of qualifications during hiring procedures, including potential formal recognition procedures.

2.7.2.Policy Options

SMEs identified the principal benefits expected from a common EU digital system as reduced administrative burden during recruitment (68%, n=108), easier assessment of non-national qualifications (63%, n=100) and faster recruitment (61%, n=97). Mean expected savings ranged from 26% on fees for recognition bodies to 36% on internal administrative time. A clear majority (71%, n=114) indicated they would be very or somewhat likely to use EU-wide digital credentials. When asked about what concerns they would have about EU-level digital credentials, the most common responses were on system compatibility (39%, n=62), legal acceptance across countries (38%, n=60), technical complexity (35%, n=56) and data privacy (31%, n=49).

3.Summary overview of results

When brought together, the consultation activities provided a coherent evidence base to draw from.

3.1.Problem definition

Public consultation respondents, call for evidence respondents, interviewees, focus group participants, expert workshop participants, issuers of qualifications and SMEs broadly identified the same set of structural challenges:

·Fragmented and unevenly implemented recognition systems;

·Persistent administrative burden, including repeated documentation requests, certified translations and high fees;

·Limited employer trust in and/or familiarity with non-national qualifications, which can be particularly challenging to address for SMEs;

·Underdeveloped systems for the validation of non-formal and informal learning;

·A digital landscape characterised by partial uptake, fragmented standards and limited interoperability.

Although the intensity of these challenges varies across MS, there were no consultation activities that contradicted this description.

3.2.Policy Options

Across all consultation activities, stakeholders supported EU-level intervention focused on improving the coherence, usability and trustworthiness of existing instruments, deepening digitalisation through interoperable and verifiable credentials, and strengthening systems for the validation of skills acquired through non-formal and informal learning. Stakeholders converged on the desirability of an EU-wide system of interoperable digital credentials underpinned by a common trust infrastructure, while still stressing the importance of human oversight, accessibility for users with limited digital literacy, and the availability of non-digital alternatives.

Several of the expert workshops emphasised the central role of trust as the operational foundation of any framework of mutual recognition, and the corresponding importance of building or strengthening the institutional networks responsible for credentialing, recognition and quality assurance. Awareness-raising and capacity-building, particularly for employers (and especially SMEs), individuals and smaller education and training providers, were repeatedly identified as essential complements to any technical or legal reform.

While the vast majority of stakeholders supported the need for EU action, there was nuance in how this should be approached. In particular, stakeholders had diverging perspectives on whether the EU should adopt new binding legislation. Public consultation respondents, trade unions and public authorities interviewed, SMEs and respondents to the call for evidence broadly supported strong EU action, sharing the view that binding measures would be necessary to drive reform at the pace required. However, employers’ organisations, several accreditation and recognition authorities, education-sector stakeholders and several interviewees in countries with mature national systems argued for caution on grounds of national competence, administrative burden, and the risk of lowering professional standards.

A second tension concerns the relative weighting of qualifications and skills in the policy approach. Higher education institutions, accreditation authorities and recognition authorities tended to emphasise the importance of preserving qualifications-based recognition and the protective role of quality assurance frameworks. Employers, trade unions, public employment services and validation authorities tended to emphasise the importance of recognising skills regardless of how they were acquired, including through non-formal and informal learning.

Annex 3:Who is affected and how?

1.Practical implications of the initiative

The Preferred Option (PO2) includes the digitalisation of all new NQF qualifications with the EUDI Wallet, of NQF qualifications issued in the past 10 years for the purpose of employment in another MS and older qualifications issued on demand for the purpose of employment in another MS, giving a legal value to digital credentials (EQF levels 2-8). As part of the preferred option, having in place a comprehensive NQF that is regularly referenced to the EQF is mandatory for MS, as is the sharing of information on qualifications in NQFs with the Europass platform. Furthermore, the Commission will make available a qualifications comparison tool. The practical implications differ across stakeholder groups.

Workers will be able to store and share digitally verified qualifications through the EUDI Wallet, reducing the time and cost currently spent obtaining, translating and submitting qualification documents to prospective employers. They will also be able to present their qualifications more clearly when looking for work in another MS. Thanks to the comparison tool they will be able to better understand how their qualification compares with other qualifications in the MS where they wish to apply for a job.

Employers will benefit from the possibility to receive qualifications in a digital format, allowing them to better understand the level and content (skills) of qualifications and to save time and effort through the possibility to instantly verify the authenticity and validity of qualifications of applicants. They will furthermore be able to easily compare qualifications of applications (whether from the same MS or from another MS) with a qualification they know, through the qualifications comparison tool and through national qualifications registers or databases if they consider that useful. The improved possibilities to understand and verify qualifications will allow employers to a achieve a better matching between candidates and jobs.

Issuing institutions will need to integrate EU digital credential issuance into their existing workflows, covering both staff training and IT system upgrades, and maintain the operational capacity to issue and validate digital credentials on an ongoing basis. They will in turn benefit from fewer queries regarding authenticity of qualifications they issued.

2.Summary of costs and benefits

The figures are presented as present value, 2026-2040, in EURO million, the benefits start to occur from year 4, after transition period.

* All costs of the preferred policy option as present value (2026–2040).

Table 21 presents a more detailed overview of costs per type of cost and stakeholder.

Table 21: Summary of cost for the preferred policy option (present value, 2026 - 2040)

3.Relevant Sustainable Development Goals

Annex 4:Analytical methods

1.For the calculations of all the costs and the calculations cost-savings for employers: The SPI Marginal Cost Model

Purpose and core method 

This model estimates the ten-year public and societal cost of the Skills Portability Initiative (SPI), comparing two technical approaches - the EU Digital Identity Wallet (Option A: Policy Options 1 and 2) and the Europass Digital Credentials (Option B: Policy Option 3) - against a defined counterfactual baseline. Every cost line is a MARGINAL cost: the difference between the harmonised SPI approach and what would most likely happen anyway without it, not the gross cost of building a digital qualification system from nothing. 

MARGINAL = OPTION (SPI-side) cost − BASELINE (counterfactual) cost 

This holds for every cost element below, calculated separately for one-off and annual costs and separately for each option - but the baseline is defined differently module by module, since "what happens anyway" genuinely differs between issuing a credential and verifying one across a border. Two mechanisms produce a marginal cost in this workbook: an explicit BASELINE-vs-OPTION subtraction (most modules), or a baseline that is genuinely zero by construction, so the gross cost already IS the marginal cost (Historical Qualifications; Verification's own infrastructure; Micro-credentials (non-NQF)). 

Cost for the EU databases (European Commission and MS)

The one shared accreditation/trust-registry build, identical whichever issuance option is chosen. 

EU-side annual MARGINAL = (SPI build × maintenance rate + EU coordination) − baseline annual running cost 

The baseline annual running cost (€800,000) is a genuine input representing what it costs to keep existing partial tools (ETER, DEQAR, etc.) running today, independent of SPI. 

Member State connection costs: a one-off build (€250,000, scaled down by each Member State's own readiness score) and annual maintenance (€50,000, set as 20% of the build cost). A separate, binary already-connected flag - distinct from the continuous readiness score - identifies MS already connected to an existing database/registry today; this flag is now populated for 16 of the 27 MS, driving a real baseline annual maintenance cost (€30,000/year) for each of them. 

The baseline rate for already-connected MS (€30,000) does not match the SPI-side maintenance rate (€50,000). Each already-connected Member State shows a real €20,000/year marginal cost: a new SPI-specific connection costs more to maintain than whatever a Member State already has.

Table 22: Cost of connection and backfill cost, scaled by readiness