EUROPEAN COMMISSION

Strasbourg, 15.9.2026

SWD(2026) 996 final

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT REPORT

Accompanying the document

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

amending Directive 2005/36/EC as regards the digitalisation of procedures and recognition of professional qualifications issued outside the Union and Regulation (EU) No 1024/2012

{COM(2026) 995 final} - {SEC(2026) 995 final} - {SWD(2026) 995 final} - {SWD(2026) 997 final}

Action 2 – Skills Portability Initiative

Table of Contents

1.Introduction: Political and legal context

1.1.Overall context of the Skills Portability Initiative

1.2.Coherence of the package

1.3Skills portability and regulated professions

2.Problem definition

2.1.What is the problem?

2.2.What are the problem drivers?

2.3.How likely is the problem to persist?

3.Why should the EU act?

3.1.Legal basis

3.2.Subsidiarity: Necessity and 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

5.2.1.Option 1 – Convergence of administrative practices through shared standards

5.2.2.Option 2 – Targeted procedural reforms for improved interoperability

5.2.3.Option 3 – Unified EU workflow and enhanced enforcement

6.What are the impacts of the policy options?

6.1.Direct cost impacts

6.1.1.Administrative cost savings and monetised time savings

6.1.2.Implementation costs

6.1.3.Costs related to expected volume increases

6.2.Broader economic impacts

6.3.Social impacts

6.4.Summary overview of impacts

7.How do the options compare?

7.1.Effectiveness

7.2.Efficiency

7.3.Coherence

7.4.Comparative overview

8.Preferred option

8.1.Option 3: Unified EU workflow and enhanced enforcement

8.2.REFIT (simplification and improved efficiency)

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

9.How will actual impacts be monitored and evaluated?

Annex 1: Procedural information

Annex 2: Stakeholder consultation

Annex 3: Who is affected and how?

Annex 4: Analytical methods

Annex 5: Competitiveness check

Annex 6: SME check

Annex 7: The PQD and the rest of the Single Market acquis

Annex 8: The landscape of regulated professions in the EU

Annex 9: Expansion of automatic recognition through CTFs

Annex 10: User journey of applicants to regulated professions

Annex 11: Measures considered

Annex 12: Discarded measures

Annex 13: Direct cost impacts

Annex 14: Diverging territorial impacts of policy options

Annex 15: Comparison of policy options

Annex 16: Monitoring indicators

Annex 17: Combined impacts of SPI Preferred Options under Action 1, 2, and 3

Annex 18: Resources – References

Glossary

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  

As underlined in the Competitiveness Compass, 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’.

Against this background, the so-called 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  The European Council underlined the need for decisive and swift action in the area of skills as a key competitiveness driver, referring to “reskilling/upskilling and lifelong learning, tackling skills and labour gaps in the context of wider demographic trends, including talent mobility to and within the European Union, and ensuring equal opportunities.” 11

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.” 12 They also underscored the need to “support Member States 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.” In March 2025, the European Commission Communication on the Union of Skills followed up on this commitment, announcing a “Skills Portability Initiative to open up more opportunities for workers and businesses to fully capture the potential of the single market.” 13  The Single Market Strategy further highlighted that lengthy and complex recognition procedures hinder mobility and labour market functioning, and that TCN face particularly significant barriers, identifying digitalisation and procedural simplification as key levers. 14

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.” 15 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. 16

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 2005/36/EC, addressing barriers to its implementation. 17 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. 18  

As part of the Fair Labour Mobility package 19 , 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 qualification 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: Removing barriers to workers’ mobility in non-regulated professions and improving availability of verifiable, secure, digitalised and interoperable information on qualifications and skills.

The first work strand of this action looks at the remaining barriers related to qualifications and skills in non-regulated professions, which constitute 78% of EU labour force. In non-regulated professions, uncertainty about how to treat qualifications obtained in another MS leads employers to request comparisons with national qualifications even though these are not legally required. These processes are often costly and time-consuming. Action 1 aims to improve clarity and thus avoid time consuming case-by-case assessments and bring simplification for employers and workers. The second work strand tackles the information gap across MS, with the aim of facilitating access to both regulated and non-regulated professions and any other use of qualifications and skills in the labour market. It aims to make all qualifications instantly understandable and verifiable for labour market actors across the Single Market by building on existing tools and setting common standards for digital credentials to be interoperable, secure, machine-readable, and allow for instant verification of authenticity and learning outcomes (knowledge, skills), thereby reducing the ‘interpretative burden’ on hiring managers, and prevent further fragmentation between MS resulting from uncoordinated investments in digitalisation. Action 1 is based on Article 46 TFEU.

Action 2: Targeted Intervention for Regulated Professions

The second action focuses specifically on improving cross-border recognition procedures for access to regulated professions. 20 There are currently over 5 700 professions regulated across the EU 21 covering an estimated 22% of the labour force 22 , 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 23 . 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 24 (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 and 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 this IA. 25 The second workstrand 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 this 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.

These three actions are closely interlinked. The interoperable, secure and verifiable digital credentials developed under Action 1 will simplify and speed up recognition procedures in the context of regulated professions under the PQD (Action 2) by reducing administrative burdens on Competent Authorities enabling smoother, faster assessments. 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 actions to facilitate recognition of qualifications of TCN is warranted. This is the purpose of Action 3.

1.1. Skills portability and regulated professions

This IA focuses on the modernisation and digitalisation of procedures under the PQD (Workstrand 2 of Action 2). 26

The regulation of professions, namely the requirement by law of specific qualifications in order to have access to professional practice, falls within the competence of MS. Justified and proportionate professional regulation serves important public interest objectives, including the protection of public health, public safety, consumers, and the natural and built environment. However, diverging access requirements to regulated professions limit professional mobility across borders, creating legal and practical barriers for professionals wishing to work in another MS and exacerbating shortages in professions. 27

In principle, cross-border recognition of qualifications for all professions where specific professional qualifications are required by law is covered by the PQD. As an exception, the PQD does not apply to notaries (Article 2(4)) and to very few professions for which other EU legislation sets out specific recognition arrangements that exclude the application of the PQD or exhaustively regulate recognition matters. For example, Directive (EU) 2022/993 on seafarers explicitly excludes the application of Directive 2005/36/EC, while specific directives on lawyers (Directives 77/249/EEC and 98/5/EC) do not explicitly exclude it and Directive 2005/36/EC could still apply on a subsidiary basis. 28  The PQD provides definitions of both a regulated profession and a professional qualification (Article 3). A regulated profession is defined as a professional activity, or group of professional activities, for which access, pursuit, or one of the modes of pursuit is subject, directly or indirectly, by virtue of legislative, regulatory or administrative provisions, to the possession of specific professional qualifications. A professional qualification is defined as a qualification attested by evidence of formal qualifications (diplomas, certificates and other evidence certifying successful completion of professional training), competence (for a training course not forming part of a certificate or diploma) or professional experience.

Professional regulation spans a wide range of sectors across the European economy. 29 The diversity of regulated professions demonstrates that regulation may be driven either by the economic importance of a profession or by the need to protect public interests such as public health and safety, consumer protection, and the quality and continuity of essential services. Regulated professions are found both in high-value-added activities, such as engineering and other technical professions, and in sectors that are critical for societal resilience and the functioning of public services, including healthcare and education. Obstacles to the mobility of professionals in these sectors can therefore generate allocative inefficiencies by preventing labour from moving where it is most needed, while also exacerbating labour shortages and constraining the provision of essential services. Health and care professions account for by far the largest share of professional recognition procedures (around 70% of establishment cases), reflecting the importance of cross-border mobility in this sector. Education represents a further 12% of establishment cases, followed by transport and machinery (6%), construction and trades (5%), and technical and engineering professions (4%). These sectors coincide with areas experiencing persistent labour shortages across the Union: four of the ten most widespread shortage occupations are in healthcare (nurses, medical specialists, nursing assistants and physiotherapists), two in transport and machinery (heavy truck and lorry drivers, sheet metal workers), and three in construction and trades (welders, electricians and plumbers). 30 This illustrates the broad economic and societal importance of ensuring that recognition procedures for professionals function efficiently across the European labour market. This broad scope of regulation of professions is evidenced by information available on the Regulated Professions Database (RegProf), which provides a comprehensive overview of professions regulated by Member States and notified under Directive 2005/36/EC. 31

Member States are required under Article 59 of the PQD to notify the Commission of the professions they regulate and the activities covered by such regulation. These notifications are made available through the RegProf database. However, the information submitted by Member States is not always complete, consistent or sufficiently detailed, meaning that the database does not currently provide the fullest overview of regulated professions across the EU.

It should be noted in this regard that the number of regulated professions is only one indicator of the extent of professional regulation in a Member State. 32 Regulatory approaches differ considerably. Some Member States regulate a broad professional field as a single profession, while others regulate individual activities within that field as separate professions. Likewise, a Member State may regulate relatively few professions but impose extensive requirements and conditions for access and pursuit, whereas another may regulate a larger number of professions subject to less stringent requirements. Consequently, the number of regulated professions provides only a partial picture of the level of regulation.

Recognition procedures under the PQD seek to reconcile the legitimate objectives pursued by professional regulation 33 with the free movement of professionals. At the same time, the responsibilities for processing recognition applications, designating competent authorities, maintaining national lists of regulated professions, and providing information to citizens lie with the MS. As a result, recognition of professional qualifications depends largely on national regulatory regimes and administrative systems.

The recognition regimes included in the Directive are:

-Automatic recognition based on EU-level minimum training requirements is applicable across all Member States and currently covers seven professions (including medical doctors and general care nurses) as well as over 50 medical and dental specialties. Under this system, the national competent authority must limit its scope to verifying whether the diploma—and any accompanying certificates—corresponds exactly to those listed in Annex V to the Directive. The authority may not check the contents of the training, meaning it must refrain from requesting documentation specifying these contents. It may, however, request other standard documents in line with Article 50 of the Directive.

-Automatic recognition for professions in trade, industry or business based on professional experience applies where the applicant’s professional activity is listed in Annex IV to the Directive.. In these cases, the national authority proceeds directly to the assessment of the professional experience documented by the applicant, which may occasionally be accompanied by specific conditions related to training.

-Automatic recognition based on Common Training Principles includes Common Training Tests (CTT) or Common Training Frameworks (CTF), which are based on an EU-level test or EU-level minimum training requirements, respectively. This regime applies exclusively within the Member States that actively participate in the specific CTT or CTF.

-The general system of recognition, under which the competent authority of the host Member State compares the applicant’s qualifications with the national training and professional requirements established by that Member State for access to the profession, and may require supporting documents to determine whether substantial differences exist that could justify the imposition of compensatory measures, where the applicant’s lifelong learning and professional experience do not compensate for those differences.

The Directive benefits not only professionals seeking long-term establishment in another Member State, but also those wishing to exercise their profession temporarily and occasionally across borders. It is thus closely linked to the Services Directive (2006/123/EC), which lays down general provisions facilitating the free movement of services within the Union. As the Services Directive itself acknowledges, its provisions give way to those of the PQD where the two overlap. This reflects the central role of the PQD in governing the mobility of professionals in regulated professions.

2.Problem definition

The decision to move and work in another Member State is influenced by a wide range of factors, including employment opportunities, wages, working conditions, language, family circumstances and broader economic conditions. 34 Recognition of professional qualifications is therefore only one of the determinants of mobility intentions. However, for regulated professions, it occupies a unique position among these factors because it constitutes a legally binding condition for access to the profession. Regardless of a professional's willingness to move or the attractiveness of employment opportunities abroad, recognition requirements determine whether they are legally permitted to practise their profession in the host Member State. Efficient and predictable recognition procedures therefore do not create mobility intentions in themselves, but they are essential for enabling existing mobility intentions to be translated into actual cross-border professional mobility. 35  This underlines the central role of the PQD in enabling the free movement of professionals in regulated professions and highlights the importance of improvements to recognition procedures assessed in this impact assessment.

An average flow of 53 000 recognition decisions per year between 2020 and 2024 with a positive recognition rate of 93% suggests that the different recognition systems offered by the Directive effectively facilitate cross-border career transitions. 36 However, the fact that, as highlighted by ECA, only an estimated 6% of citizens aged 20 to 64 years moving to another MS make use of the systems of recognition of professional qualification, while regulated professions account for approximately 22% of the EU labour market, suggests that professional mobility in regulated professions remains below its potential. 37  

The Commission's preparation of the Report on the implementation of the PQD covering the period 2020–2024 and its accompanying SWD, adopted in February 2026, provided a significant opportunity to assess the functioning and implementation of the PQD in practice. Based on extensive evidence gathering and consultations with CAs, professional organisations, citizens and other stakeholders, the exercise identified a number of persistent shortcomings and implementation challenges. 38  

In addition to drawing on the evidence collected for the implementation report, the study supporting this IA 39  was informed by desk research, evidence from the Regulated Professions Database (RegProf) 40 and the Internal Market Information System (IMI), 41 and stakeholder consultations. Although these sources provided a sufficient evidence base for the assessment, important data limitations remain, notably inconsistent reporting by MS, limited operational metrics on the performance of recognition procedures and insufficient data on “potential mobility”. These limitations are linked to the still limited digitalisation of recognition systems, which results in fragmented data collection.

2.1.What is the problem?

Despite the existence of an EU legal and policy framework supporting the cross-border recognition of professional qualifications, mobile professionals still face considerable practical and administrative hurdles when trying to access regulated professions in another MS. Applicants seeking to have their qualifications obtained in one MS recognised in another MS to access a regulated profession often face long, complex and burdensome recognition processes. 42  Professionals are deterred from pursuing cross-border opportunities 43 . This translates into limited recruitment options for companies, who find themselves unable to easily tap into the full EU talent pool to fill critical vacancies. 44  At macro-economic level, barriers to recognition contribute to an inefficient allocation of skills across the EU, with negative effects on labour mobility, productivity and potential economic growth, 45 and reinforce uneven mobility patterns contributing to brain drain from certain MS. When the recognition of qualifications is stalled or denied, skilled professionals are forced into roles that do not utilise their full expertise, contributing to “brain waste” and overqualification. 46 This is evidenced by the considerably higher than average overqualification rates for mobile workers in the EU: 31.3% for mobile EU citizens vs. 20.8 for domestic workers in 2023. 47  

The problems and their underlying drivers identified in the 2020–2024 report on the implementation of the PQD, as discussed further below, reflect challenges that have persisted over time,

The 2011 evaluation of the Directive 48 had already observed that the general system of recognition provided a pragmatic and effective solution, but that its application remained burdensome for professionals and competent authorities. Regarding the automatic system, it had found that it allowed overall for efficient treatment of requests for recognition. The evaluation identified weaknesses in the consistency and accessibility of information, complex procedures, limited administrative cooperation and limited availability of electronic procedures. Although the PQD had strengthened and simplified administrative cooperation, information exchanges were limited, and while the IMI system had significantly improved the speed and efficiency of cooperation, its effectiveness was constrained by the fact that its use was not mandatory for all professions and competent authorities.

In response to these findings, a number of reforms were introduced by Directive 2013/55/EU 49  aimed at improving the efficiency, transparency and digitalisation of recognition procedures. These included the creation of the European Professional Card (EPC), an electronic procedure applying to professions for which the Commission would subsequently adopt an implementing act, 50 allowing professionals to submit applications for the recognition of qualifications or declarations for the temporary and occasional provision of services through an online platform. The EPC was intended to simplify administrative procedures, reduce processing times and strengthen cooperation between competent authorities through the IMI system. The revision also introduced an alert mechanism requiring Member States to notify each other when professionals had been prohibited or restricted from exercising their profession, strengthened rules on administrative cooperation and information exchange, expanded the information to be made available online on recognition procedures, required the possibility to complete procedures by electronic means, established assistance centres to support professionals, and reinforced transparency obligations concerning regulated professions. These reforms produced improvements. IMI provided competent authorities with a common, secure and structured channel for identifying and communicating with their counterparts. It improved authority-to-authority cooperation, trust and traceability. The EPC demonstrated that a faster and more transparent electronic recognition procedure was possible by establishing a structured online workflow, allocating responsibilities between the home and host authorities and setting specific procedural deadlines.

In 2018, the Commission published an assessment of stakeholders' experience with the EPC and the alert mechanism. 51 The assessment concluded that the EPC and the alert mechanism made a positive contribution to the objectives of the 2013 revision of the PQD, providing added value compared to the 'traditional' processes and facilitating information exchanges. The evaluation demonstrated a high interest of the users in the EPC and an increasing use of the alert mechanism by Member States. The public authorities appreciated both EPC and the alert mechanism as secure tools for information exchanges and as a useful facilitation. At the same time, the assessment highlighted the need for continuous improvements, including further refinement of IMI functionalities, enhanced guidance for competent authorities, more transparency, and ongoing dialogue with users to ensure the effective and consistent operation of these new digital tools.

The 2020 implementation report 52 concluded that the revised PQD had been broadly effective in facilitating the mobility of professionals across the EU. The digital tools introduced by the 2013 revision were found to support administrative cooperation and the recognition process effectively. At the same time, the report found that Member States continued to impose burdensome procedural requirements, failed to provide comprehensive online information and electronic procedures, and did not fully comply with transparency obligations. The mutual evaluation exercise had not resulted in regulatory reforms, while proportionality assessments of professional regulation were often insufficient. In addition, several issues remained open, particularly concerning language checks, temporary service provision and partial access. The report confirmed further the need to refine the IMI platform.

In 2024, the European Court of Auditors published a special report on the recognition of professional qualifications in the EU  53 concluding that, although the EU system for the recognition of professional qualifications is essential for supporting labour mobility, it is applied inconsistently and remains burdensome. It recommended that the Commission strengthen the uniform implementation of the Directive through clearer guidance, better monitoring and enforcement, and greater consistency in the application of procedural requirements and deadlines. The report also called for stronger integration of the alert mechanism into recognition procedures, faster and more efficient automatic recognition for sectoral professions, including shorter decision deadlines, and more reliable, complete and consistent information for professionals.

The findings of the 2026 implementation report 54 largely confirmed the earlier diagnosis. Recognition procedures may still be lengthy and complex, national digitalisation remains uneven, documentary requirements can be burdensome, and information available through national portals and EU-level sources is not always complete, consistent or up to date. The persistence of these problems does not mean that the reforms adopted since 2011 were ineffective. Rather, they improved specific parts of the system without comprehensively redesigning the recognition process.

As regards the EPC, the predecessor of the broader IMI-based digital workflow introduced by this proposal, the evidence collected for the 2026 Implementation Report indicated that, despite its potential, its impact has remained constrained by a range of operational and systemic challenges. Targeted consultation highlighted that the IT system underpinning the EPC is often perceived as complex, rigid and cumbersome to operate. Document uploads are considered time-consuming, navigation is not sufficiently intuitive, and the overall workflow is regarded as more burdensome than national procedures or the standard recognition procedures. Technical and interoperability issues, linked in particular to uneven levels of digitalisation across Member States, have further hindered its effective functioning. In addition, low awareness among both professionals and competent authorities has limited its uptake. Since the EPC does not automate or simplify key administrative tasks, such as verifying the authenticity of documents or classifying supporting evidence, these continue to require significant manual effort by competent authorities. Overall, the evidence pointed to the need for a more unified and scalable digital approach that strengthens the mutual trust underpinning the PQD while improving efficiency, transparency and the user experience.

A comparison with the 2011 evaluation therefore shows continuity rather than the emergence of entirely new problems. Previous reforms successfully improved administrative cooperation and demonstrated the benefits of electronic recognition procedures, but their scope and design prevented them from resolving the problems across the Directive as a whole. 55 The remaining challenge is to build on those reforms through a scalable, interoperable and user-centred digital process covering the full recognition workflow.

As explained in more detail below, the remaining inefficiencies stem from several interrelated causes. Processing times and administrative burdens are influenced by a combination of factors affecting both applicants and competent authorities. The provision of information constitutes the first of these. While Member States and competent authorities remain responsible for maintaining information on regulated professions, competent authorities and national requirements, insufficient alignment between national and EU-level information sources can lead to inconsistencies, reducing the reliability and clarity of the information available. As a result, applicants are not always sufficiently informed about the applicable requirements, leading to incomplete applications and additional exchanges with competent authorities. Recognition procedures are fragmented across a large number of competent authorities with differing workloads, resources, levels of expertise, administrative capacities and exposure to cross-border mobility in regulated professions. The workload associated with the recognition of professional qualifications is not limited to assessing applications and determining whether qualifications are equivalent. Competent authorities also devote considerable resources to supporting administrative activities, such as maintaining information portals, responding to enquiries from applicants and other competent authorities, issuing certificates for outgoing professionals, and managing information in the Regulated Professions Database. These horizontal tasks are indispensable for the functioning of the recognition system and represent a significant share of the overall administrative effort required from competent authorities. Authorities operating under the general system frequently have to assess qualifications obtained in different education and training systems, making recognition procedures inherently more complex. Delays may also arise when information must be obtained from competent authorities in other Member States. These challenges are compounded by uneven levels of digital maturity. Existing digital tools do not always communicate effectively with one another, requiring manual interventions and duplicative work, while some authorities continue to rely on paper-based or only partially digital processes. Recognition procedures also continue to depend heavily on documentary evidence whose authenticity must be verified on a case-by-case basis. In the absence of interoperable and widely verifiable digital qualifications, competent authorities often request certified copies, translations or additional attestations, increasing both the administrative burden and the duration of procedures. Although IMI provides a common channel for administrative cooperation, the Directive does not sufficiently regulate intermediate procedural steps or authority-to-authority exchanges, and certain procedural obligations lack the precision needed to ensure consistent implementation. Consequently, delays often arise not from an unwillingness to cooperate but from divergent national workflows, differing administrative practices and the absence of common operational processes.

These issues give rise to the problem drivers analysed in the following section.

2.2.What are the problem drivers?

The problem identified above can be broken down into three underlying problem drivers. These drivers arise from a combination of divergent national regulatory frameworks, differing administrative practices across MS, and, in some areas, provisions of the PQD that leave scope for varying interpretations.

When analysing the drivers of the identified problems, it is useful to distinguish between issues of design and issues of implementation. Design issues arise where the Directive does not provide a common element that is instrumental for the effective functioning of the recognition system, such as a common workflow or other shared procedural arrangements. 56 Implementation issues arise where the Directive already contains the relevant elements, but they are either not defined with sufficient specificity to support consistent application across Member States or are not correctly applied in practice. As explained below, the analysis identifies both types of issues.

Fragmented and inconsistent information available to applicants

In this area, the main challenge lies not so much in the design of the framework established by the Directive as in its implementation. While the necessary elements are largely in place, they are not implemented consistently or in a sufficiently aligned manner across Member States.

Individuals seeking to access or exercise a regulated profession in another MS must comply with national rules governing access to that profession. As a first step, applicants therefore need access to clear, comprehensive and up-to-date information on applicable national requirements. The PQD requires MS to ensure centralised access to information through Points of Single Contact (PSCs) and provides for the establishment of Assistance Centres (ACs) to support applicants in navigating national procedures and legislation. 57 In addition, the Single Digital Gateway Regulation 58 introduces additional digital access and online service availability obligations. Despite this, however, professionals still encounter practical difficulties in accessing reliable and user-friendly information: information is often fragmented across multiple institutional sources. 59 While some MS provide comprehensive and centralised information, 60 the availability, accessibility and quality of information vary significantly across professions and MS. 61 The fragmented and inconsistent information contributes to incomplete or incorrect applications 62 and generates repeated requests for clarification addressed to CA. 63  National business federations flag that companies find it difficult to assess whether qualifications obtained in one country meet the requirements of another country. 64  Although the applicable legal framework requires alignment between information available at EU and national level, inconsistencies persist, such as discrepancies between the lists of regulated professions published in the RegProf database and those available on national websites. 65  Although the PQD requires MS to notify to the Commission their lists of regulated professions, specifying the activities covered by each profession, in practice only some MS provide continuous updates while others do so only periodically. 66 On the other hand, while MS are required by the PQD to provide information at national level, the legal framework does not always specify in sufficient detail the content of that information, resulting in variations in quality and completeness. 

Process inefficiencies

In this area, the main challenge lies in the design of the recognition framework. The Directive does not establish a common workflow or sufficiently harmonised procedural rules for how recognition procedures should be conducted, resulting in divergent national processes and associated inefficiencies.

Evidence gathered in the context of the 2020–2024 PQD implementation report highlights concerns about heavy procedural requirements and the continued reliance on paper-based submissions in some MS. 67 Professionals face difficulties due to a lack of streamlined processes. 68  Recognition procedures under the PQD are resource-intensive. 69  CA for professions subject to the general system of recognition requiring an individual assessment of qualifications find that staffing constraints and high workloads result in delays. 70 Automatic recognition, although it is based on harmonised minimum training requirements, in practice remains far from fully automatic — checks of documents and exchanges with CA in the home MS continue to rely on manual processing and require significant human resources. 71 While the PQD provides for legally binding procedural deadlines, they are not consistently respected. 72 Many MS still require physical submission of documents as fully digital procedures are not always available. 73 For applicants, this reliance on physical documentation increases costs 74 , administrative burden, and delays. 75 Documentation requirements, although defined and limited under the PQD, often exceed what is strictly necessary in practice, including certified originals, notarised copies, apostilles, and sworn translations. 76 This is often linked to a lack of trust in qualifications issued in other MS. 77 Certified translations and copies generating additional costs and delays particularly where multiple documents must be processed. Finally, as the PQD leaves to MS to define recognition fees, both the level and structure of fees vary widely, creating uncertainty for applicants which may discourage them from applying. 78  

Fragmented administrative cooperation among national authorities and between national authorities and the Commission

This problem reflects both shortcomings in the design of the current framework and in its implementation. The absence of a common workflow is compounded by inconsistent implementation of existing cooperation mechanisms, resulting in fragmented exchanges and cooperation.

Cooperation among MS is primarily supported by IMI, which provides a secure communication platform for CA to exchange information. Despite the support provided by IMI, coordination challenges, stemming from differences in national administrative structures and the level of engagement across MS complicate implementation. 79 Inconsistent use of the IMI undermines its potential to support administrative cooperation under the PQD. 80 The EPC remains underutilised and its uptake varies significantly across MS and professions. 81 More broadly, recognition procedures across the EU are still unevenly digitalised. 82 Although many MS have introduced online portals and digital document upload functionalities, professionals frequently encounter hybrid systems combining digital and paper-based elements. 83 Interoperability issues between national systems further exacerbate these challenges. Cooperation via the IMI system does not currently function as a tracking tool for the entire recognition procedure. Significant data gaps persist, most notably concerning the actual duration of recognition procedures from the moment of initial application to the final decision. Resolving these gaps currently requires substantial administrative effort and results in an incomplete evidence base. 84 Ultimately, this lack of transparent, real-time data limits the Commission's enforcement capabilities, making it difficult to identify systemic delays or effectively hold MS accountable to legally prescribed deadlines.

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   The problem drivers described above are represented in the visual below, which sets out the intervention logic of the initiative. In addition to illustrating the overall problem and its underlying drivers, it captures the key issues identified and the objectives pursued in relation to each problem driver.

As illustrated in Annex 10, the shortcomings identified above can have a compounded negative impact across the entire user journey. When information gaps, procedural hurdles, and administrative cooperation bottlenecks converge, they create a cumulative 'friction' that fundamentally compromises the applicant's experience. The initial difficulty in finding reliable information often leads to incomplete or incorrect applications, which creates delays at the very beginning of the process. These can be further exacerbated by burdensome, paper-based processes and uneven cooperation between the CA, where administrative inertia of a single authority can stall the entire process. Finally, a lack of precise real-time data on processing times hampers the effective monitoring of compliance.

2.3.How likely is the problem to persist?

In the absence of additional EU action, some gradual and incremental improvements can be expected as a result of improved technical infrastructure and the use of possibilities already provided under the PQD. 85 However, in the absence of more systemic reforms the portability of qualifications across borders will continue to be hampered. As indicated above, the number of regulated professions in the EU has remained constant at a high level between 2016 and 2023. 86 Since the regulation of professions is within the competence of the MS, administrative obstacles arising from differences in national regulatory requirements are not expected to decrease. In response to technological change, digitalisation and the shift towards a net-zero emissions economy, MS are revising existing regulated professions or even defining new ones to ensure safety and quality in both emerging and established sectors. 87 They are likely to continue to do so in the coming period. In the absence of central coordination, this will create additional regulatory divergence for a considerable share of professions. Technical improvements within individual MS will not automatically yield system-wide benefits, as the overall speed of recognition procedures remains critically dependent on the quality of bilateral cooperation. The uneven uptake of digital tools across the Union creates "bottlenecks" where the inefficiencies of one national authority hinder the cross-border process. Digitalisation at individual MS level can even hamper rather than smoothen recognition, by making interoperability more difficult. Furthermore, the PQD in its current form does not provide the operational metrics needed to monitor the end-to-end performance of recognition systems, nor does it ensure the systematic collection and transmission of relevant data between CA and to the Commission. In the absence of additional measures, these data limitations will continue to hamper monitoring and enforcement.

3.Why should the EU act?

3.1.Legal basis

The legal basis for this policy action is Article 53(1) of the Treaty on the Functioning of the European Union (TFEU), which empowers the Union to adopt directives for the mutual recognition of diplomas, certificates and other evidence of formal qualifications, as well as for the coordination of national provisions governing access to and pursuit of regulated professions, including for self-employed persons 88 . This provision, in conjunction with Articles 45, 49 and 56 TFEU on the free movement of workers, freedom of establishment and freedom to provide services, underpins Directive 2005/36/EC on the recognition of professional qualifications. The present initiative does not alter the substantive scope or overall architecture of the Directive, nor does it harmonise national rules on the organisation of professions or qualification requirements. The envisaged measures fall within the scope of Article 53(1) TFEU, as they aim to facilitate the effective recognition of qualifications and thereby enable access to regulated professions across MS.

3.2.Subsidiarity: Necessity and added value of EU action

The initiative concerns the functioning of the internal market, which is an area of shared competence between the Union and the MS pursuant to Article 4(2)(a) TFEU. Accordingly, the principle of subsidiarity applies. The existence of an EU legal framework in the form of the PQD since 2005, and the decision to maintain this instrument as the reference framework while amending and modernising it in 2013, illustrate the common understanding that EU-level action in this area is both necessary and appropriate. The need for Union action thus arises not only from the rationale for mutual recognition as such, which is already established, but from persistent shortcomings in the practical functioning and enforcement of an existing EU framework. The initiative aims to improve this pre-existing legal framework for recognition at EU level. Changes to the EU framework can only be done by EU level action. Recognition procedures inherently require interaction between CA in different MS, including the exchange and verification of information, validation of qualifications, and clarification of documentation. Unilateral efforts by MS to streamline their own procedures do not resolve these cross-border frictions, as they neither ensure reciprocity nor establish common operational rules for cooperation. These issues are structural and cross-border in nature and cannot be adequately addressed through isolated national measures Without coordinated action at Union level, the system remains dependent on heterogeneous practices and ad hoc communication, limiting the potential for simplification and efficiency gains. Moreover, the integration of digital tools to facilitate recognition procedures requires a common framework to be effective. If developed separately at national level 89 , such tools would risk fragmentation, duplication and lack of interoperability.

Union action is also necessary to strengthen transparency and enforcement of the existing rules. At present, the monitoring of recognition procedures relies largely on MS’ self-reported data and individual complaints, which does not provide a comprehensive or reliable basis for assessing compliance and to enforce the rules in the event of systematic incompliance. Action at EU level is needed to ensure consistent and comparable data to support both national and EU-level corrective measures. Such transparency cannot be achieved through uncoordinated national systems. In the absence of Union intervention, the identified problems are likely to persist, resulting in continued delays, administrative burdens and legal uncertainty for applicants and CA. Coordinated EU action is therefore necessary to ensure that the existing framework operates as intended and that the rights conferred by the Treaties can be effectively exercised in practice. A further coordinated EU framework would lead to more consistent and reliable recognition decisions across MS. By streamlining information requirements, deadlines and cooperation practices, the initiative would reduce variability in how similar cases are handled and limit the risk of divergent or conflicting assessments. This can also facilitate the availability of reliable and comparable data, reduce administrative effort, lower reporting costs, and minimise risks of errors or inconsistencies, while enabling more timely and accurate monitoring.

EU-level action also offers clear economies of scale and avoids duplication of efforts. A common EU approach to streamlining key aspects of the recognition process is more cost-effective than multiple parallel national solutions, which may be incompatible or require complex interfaces. EU-level intervention ensures interoperability, thereby maximising the benefits of digitalisation and preventing fragmentation. While Union action requires initial adaptation efforts by national administrations, including changes to existing procedures and systems, these costs are expected to be offset by long-term efficiency gains, reduced administrative burden, and improved service delivery. Overall, EU action provides a more efficient and coherent solution than uncoordinated national approaches, delivering benefits that cannot be achieved at the same scale or consistency by MS acting alone.

4.Objectives: What is to be achieved?

The PQD has long provided a solid legal framework for the recognition of professional qualifications across MS, consolidating several previous instruments in this area. This initiative does not seek to overhaul the system established by the Directive, the effectiveness of which is evidenced by a constant stream of positive recognition procedures. 90 Rather, it aims to identify and address specific pain points, including both underutilised opportunities and persisting obstacles. Accordingly, the initiative is designed to remain proportionate and targeted, addressing only those issues that require action. Its objective is not to create a new system, but to introduce focused improvements to enhance the functioning of the existing framework. 91

4.1.General objective

The general objective of the action is to ensure the free movement of workers 92 in regulated professions across the EU. This contributes to the Union’s overarching policy objective of deepening and strengthening the Single Market as a driver of competitiveness, resilience and sustainable growth, as reflected in recent Commission priorities and strategic reflections on Europe’s economic performance. In this context, the action supports the objectives of the Union of Skills, notably by enhancing the portability and recognition of skills and qualifications, facilitating cross-border recruitment, and improving the matching of skills supply and labour market demand across MS. Furthermore, the initiative contributes to addressing structural labour shortages and skills mismatches, thereby supporting productivity growth and the efficient allocation of human capital, in line with the Union’s broader competitiveness and innovation agenda. By promoting interoperable recognition systems through the uptake of digital tools, the action also aligns with the EU’s digital transition objectives and the development of a more integrated and future-proof Single Market.

4.2.Specific objectives

This intervention is structured around three specific objectives, each addressing one of the identified problem drivers. For each objective, a corresponding reference is proposed. The latter are intended as concrete benchmarks rather than exhaustive reflections of the specific objectives they refer to. Acknowledging that quantitative indicators cannot fully capture the multifaceted nature of the problem drivers, they provide the essential empirical standards required to drive accountability and evaluate the intervention's impact. 93  

The first specific objective proposed (SO1) is to ensure that information on qualification requirements and recognition procedures at national level is complete, clear and easily accessible, in a manner that is consistent with the information made available at EU level under the PQD. The proposed point of reference for achieving this objective is the establishment of a single, reliable and up-to-date EU-level source of information, enabling applicants, employers and competent authorities to access accurate and comparable information across Member States. The second specific objective (SO2) is to make recognition procedures faster, simpler and less burdensome. The proposed benchmark for achieving this objective is a 25% reduction in the overall cost of recognition procedures compared to the baseline. 94  The third specific objective (SO3) is to improve cooperation and communication among national competent authorities responsible for recognition procedures, as well as between national authorities and the Commission. The proposed point of reference for achieving this objective is ensuring that requests for administrative cooperation are answered within a maximum period of two weeks, as a general rule.

The three Specific Objectives are closely interrelated and mutually reinforcing, as they address different but interdependent drivers of the same underlying problem. SO1 (clear and complete information) functions as a precondition for the effective operation of the system. When applicants have access to accurate, complete and consistent information on qualification requirements and recognition procedures, they are better able to identify the appropriate CAs and submit complete applications. This directly supports SO2, by reducing errors, requests for clarification and resubmissions, and indirectly supports SO3, by limiting avoidable information exchanges between authorities. SO2 (faster and less burdensome procedures) addresses the operational efficiency of recognition processes once applications are submitted. Streamlined procedures, clearer deadlines applicable across all recognition paths, and greater use of digital tools reduce processing times and administrative effort for both applicants and CAs. SO3 (improved administrative cooperation) underpins both SO1 and SO2 by strengthening trust, communication and consistency among CAs, and between them and the Commission. More timely and structured cooperation contributes to the accuracy and updating of information provided to applicants (SO1), and enables faster handling of cross-border verifications and recognition decisions (SO2).

The benchmarks proposed above are reflected in the indicators included in the monitoring framework presented in Chapter 9 and Annex 16. These indicators will be used to track progress towards the specific objectives and assess whether the initiative is delivering the expected results. The direct impacts of the initiative are expected to start materialising from 2029, once the implementation phase of the European Digital Recognition System (EDRS) in 2027 and 2028 has been completed. Wider impacts, including effects on professional mobility, labour market functioning and the overall performance of recognition systems, are expected to emerge progressively thereafter. Evaluating the initiative five years after the expiry of the transposition deadline 95 would allow sufficient time for both the direct impacts and the broader effects of the initiative to become observable.

5.What are the available policy options?

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

If no new measures are introduced at EU level, the Commission would continue to implement and enforce the current legal framework while MS would continue to make use of existing instruments at differing speeds, depth and levels of effectiveness.

Digitalisation of recognition‑related processes would continue to advance, driven not only by the gradual rollout of the European Digital Credentials and national e‑government reforms, but also by the ongoing implementation of EU‑wide digital enablers, notably the Single Digital Gateway Regulation, the Once‑Only Technical System 96 and the deployment of the EU Digital Identity Wallet. 97 While these initiatives are not specifically designed for the recognition of professional qualifications, they provide concrete, Commission‑developed tools that can be leveraged to streamline recognition procedures. Under the baseline, however, without any initiative to at least encourage, if not actively monitor, integration of these tools, results would remain partial and uneven across MS and professions, with significant untapped potential.

Under the baseline, incremental improvements in certain aspects of recognition processes can be expected by 2030. Continued progress in national referencing to the EQF and the availability of EU‑level transparency tools (e.g. Europass, ESCO) are likely to enhance formal comparability of qualifications and mutual understanding between authorities. The gradual uptake of digital credentials and authentication tools may reduce fraud risks and enable faster checks in those MS and professions where such tools are fully integrated into administrative workflows. However, these improvements are unlikely to translate into system‑wide efficiency gains. The voluntary and non‑binding nature of most EU instruments means that procedural requirements, documentation standards, timelines, fees and appeal mechanisms are expected to remain diverse across MS. Fragmented digital uptake, the continued reliance on hybrid or paper‑based procedures in many jurisdictions, and limited end‑to‑end interoperability between national systems are likely to constrain the practical usability of digital solutions.

Another dimension of the baseline concerns the continued use and development of Common Training Frameworks (CTFs). 98 The Commission is already actively working on this instrument and intends to continue advancing it in close cooperation with MS. As part of the SPI, specific professions have been identified as prime candidates to pilot and expand this collaborative framework. These include professions that are crucial for the EU’s overall competitiveness and innovation potential, such as civil engineers and biomedical laboratory technicians; professions that play a key role in the green transition, including electricians, heating, ventilation and air-conditioning technicians, and landscape architects; as well as several care professions, such as nursing and health care assistants, occupational therapists and radiographers, and professions related to education, including kindergarten teachers and child care workers. A streamlined approach to CTFs will yield tangible time and cost savings for applicants while significantly freeing up administrative resources for CAs. However, while CTFs deliver substantial, targeted benefits for the professions involved, the instrument is subject to structural limitations. Because it relies on a high baseline of existing alignment of national regulatory measures, a CTF can only be successfully deployed for a restricted number of professions. Furthermore, its ultimate success and take-up remain highly dependent on the political willingness of MS to implement it within their domestic legal systems. In conclusion, while expanding the use of CTFs in the future will successfully eliminate recognition frictions for specific mobile professionals, it is no substitute for a broader systemic reform on national level to ensure that regulation remains proportionate and is not expected to yield in itself across-the-board efficiency gains across the wider EU labour market.

Although the available evidence does not establish that the existing shortcomings will necessarily worsen over time, it is likely that consequences will become more pronounced in the absence of further action. This reflects broader developments affecting the context in which the Directive operates.

First, demographic change is reducing the size of the available workforce. The EU's working-age population is projected to shrink significantly over the coming decades, exacerbating labour and skills shortages across many sectors. 99 As Member States increasingly rely on the mobility of qualified professionals to address these shortages, recognition systems will need to process a growing number of applications efficiently and without unnecessary administrative burden.

Second, demographic ageing and increasing life expectancy are driving demand for healthcare and long-term care services, many of which are delivered by regulated professionals. At the same time, persistent labour and skills shortages will make it increasingly difficult for Member States to meet this demand from the domestic workforce alone. As a result, cross-border mobility of regulated professionals is expected to play an increasingly important role in addressing workforce needs.

Then, the green and digital transitions are transforming labour markets by creating demand for new skills and occupations and by changing the competences required in existing professions. This is likely to lead to more updates to training curricula, greater diversity of qualifications and, where appropriate, the regulation of new professions, increasing the complexity of recognition decisions. 100

Finally, rapid technological progress and the digitalisation of public administration continue to raise the expectations of citizens and businesses for digital, user-friendly, interoperable and efficient public services. Recognition procedures that remain fragmented, paper-based or insufficiently digitalised risk becoming increasingly out of step with these expectations.

Against this background, administrative workloads are likely to increase faster than the coordination capacity, digital maturity and institutional resources of competent authorities. This may result in greater risks of delays, backlogs and inconsistent decision-making, particularly in professions characterised by high mobility or persistent labour shortages. Professionals may continue to experience delayed labour market entry or under-employment, while employers, especially SMEs, may face continuing difficulties in recruiting qualified professionals across borders despite persistent vacancies.

Overall, it cannot be concluded with certainty that recognition systems will perform worse under the baseline scenario. However, as external pressures intensify, the existing shortcomings of the framework are likely to become increasingly consequential. In this context, addressing these shortcomings becomes progressively more important to ensure that recognition systems remain efficient, responsive and capable of supporting the evolving needs of the Single Market.

5.2.Description of the policy options

Three policy options are presented below. Each option comprises a set of measures designed to contribute to all specific objectives and address all three problem drivers. Within each option, the measures proposed are broadly consistent in their nature, ranging from non-legislative measures to legislative measures combined with enforcement mechanisms. Moving from one option to another, the degree of ambition to ensure integrated results progressively increases. In a limited number of cases, a measure has been retained in a subsequent option where it remained compatible with the overall logic of that option and was not rendered unnecessary by other, more far-reaching measures. The analysis below is complemented by Annex 11, which presents and describes the specific measures included under each option. 101

5.2.1.Option 1 – Convergence of administrative practices through shared standards

This option relies on non-legislative measures to complement the existing EU legal framework, such as Commission guidance, common templates and voluntary peer reviews, to streamline administrative practices. It improves information quality by promoting interoperable information architectures and aligning EU-level sources with national sources and enhancing the clarity and consistency of national information. It promotes process efficiency and transition from paper-based processes to digital procedures, and supports in that context faster processing with fewer documentary requirements. To facilitate procedures, it introduces voluntary tools and soft measures, including an EU-developed AI-assisted workflow system, indicative shorter deadlines where applicants make use of EU digital credentials, shared standards for digital interoperability, and updated Code of Conduct provisions on proportionate documentation and reasonable fees. Cooperation among CA is reinforced through nonbinding IMI response deadlines, expanded training on digital tools, and encouragement to conduct recognition procedures fully online while allowing MS to choose their own systems. This approach acknowledges the diversity of national contexts and operational needs - for instance, differences in the number of CA, application volumes, or available administrative capacity – and consists of improvements which can be implemented without imposing uniform procedural requirements. 

Policy measures proposed under PO1

5.2.2.Option 2 – Targeted procedural reforms for improved interoperability

This option introduces specific legislative amendments to the Directive aimed primarily at supporting the digitalisation and interoperability of recognition procedures across MS, while preserving flexibility for national administrations in the organisation of their workflows. It supports improved information through automated updates of the RegProf and the possibility to deploy a chatbot to support applicants. It also improves the management of digital workflows while maintaining national flexibility. Some process improvements rely on voluntary uptake (e.g. an AI-assisted workflow tool would be made available by the Commission for national systems to integrate it at their own discretion) whereas others would be mandatory (e.g. verifiable, interoperable digital credentials would be mandated for the professions under automatic recognition). The identification of specific deadlines for each step of the recognition process, with a focus on the cooperation between CA, would help structure it and support shorter processing times. Documentation, translation requirements and fee practices would be further clarified by non-binding recommendations in the Code of Conduct. Binding deadlines for responses to administrative assistance requests would be introduced, while allowing MS to use their existing national digital workflows under a “digital first” principle. This option effectively structures the recognition process and data exchange without mandating a specific EU-wide digital workflow.

Policy measures proposed under PO2

5.2.3.Option 3 – Unified EU workflow and enhanced enforcement 

This option constitutes a comprehensive procedural reform of the existing legal framework through legislative amendments, mandating a single EU-wide digital workflow across all MS. It ensures the completeness and clarity of information on recognition requirements and procedures by further specifying the information to be provided at national level and by enabling the automated updating of RegProf. It introduces a mandatory EU-wide digital workflow incorporating an AI-assisted management system to be integrated into a harmonised digital procedure applicable across all MS. 105  Legally binding deadlines for every procedural step are reinforced by a financial compensation mechanism for administrative delays. The option also introduces a significant reduction in documentation and translation requirements, while fees would also be standardised. Through binding deadlines with penalties for non-compliance, and mandatory training to CAs for all new tools and processes, the option also strengthens administrative cooperation and coherence in the recognition system and ensures consistent and simplified user experience throughout the Union.

Policy measures proposed under PO3

The European Digital Recognition Solution

Design and operation

The preferred option establishes a single European Digital Recognition Solution (EDRS) supporting the complete workflow for the recognition of professional qualifications. The system does not harmonise national recognition rules or affect Member States' competence to regulate professions or decide on recognition requests. Competent authorities remain fully responsible for assessing applications and taking recognition decisions in accordance with national law and Directive 2005/36/EC. The initiative only harmonises the workflow.

The proposed digital solution covers the entire recognition procedure from end to end. It provides applicants with a single entry point where they can identify whether a profession is regulated in the Member State of destination, understand the applicable requirements, prepare and submit their application, upload supporting documents and follow the progress of their case. For competent authorities, the system provides integrated workflow management, document management, communication with applicants and other competent authorities, support for the assessment process, issuance of decisions and automatic statistical reporting. It therefore replaces fragmented procedural arrangements with a single digital workflow applicable across all professions and all competent authorities.

This represents a significant evolution compared with the current situation. Recognition procedures remain predominantly national, with varying degrees of digitalisation. Some competent authorities rely entirely on paper-based procedures, others operate partially digital systems, while others have developed national online portals covering only specific parts of the procedure. 106 At EU level, digital cooperation is currently limited mainly to the IMI system, which facilitates administrative cooperation between competent authorities, and to the EPC, whose digital workflow applies only to a limited number of professions. The preferred option builds on these existing instruments while extending digital processing to all professions covered by the Directive.

In practice, the recognition procedure would operate through a single workflow. An applicant wishing to establish in another Member State would first access the digital interface to obtain information on the applicable recognition procedure and the documents required. Where available, applicants could submit digital credentials issued under the EUDI framework or evidence retrieved through the SDG and the OOTS. Where equivalent digital evidence is not available, or where applicants have limited digital skills or access to digital tools, competent authorities would continue to accept non-digital submissions and, where necessary, digitise the application and manage it within the system on the applicant's behalf. This ensures that digitalisation improves efficiency without excluding any applicant.

Once the application has been submitted, it is made accessible by the competent authority of the host Member State. The authority performs the preliminary verification of completeness within the deadlines established by the Directive, requests any missing information where necessary and communicates with applicants directly through the system. Where cooperation with authorities in another Member State is required, all exchanges also take place within the same workflow. Throughout the procedure, applicants can monitor the progress of their application, while competent authorities benefit from automated workflow management, deadline monitoring and secure document handling.

The system would also include digital support functions designed to reduce administrative burden while leaving all substantive decisions to competent authorities. Artificial intelligence tools would support the automatic translation of documents submitted in any official Union language, facilitate document classification, compare submitted evidence against the procedural requirements applicable to each profession and assist in identifying potentially fraudulent or inconsistent documents. These functionalities support administrative processing but do not replace the assessment carried out by competent authorities, which remain solely responsible for the recognition decision.

The preferred option also provides a clear allocation of responsibilities between the Commission and Member States. The Commission would design, develop, operate and maintain the common digital infrastructure extending the existing IMI platform. It would be responsible for the technical operation, cybersecurity, maintenance, future upgrades and interoperability with other Union digital infrastructures. Member States would continue to designate competent authorities, process applications, communicate with applicants, assess qualifications and adopt recognition decisions in accordance with their national legislation. The Commission therefore provides the common procedural infrastructure, while Member States retain full responsibility for the substantive recognition procedure.

Unlike the intermediate policy option, the preferred option does not require Member States to develop or maintain separate national workflow systems. The common European workflow constitutes the operational system used by all competent authorities. Consequently, interoperability with national recognition systems is not required because recognition procedures are managed directly within the common infrastructure. This considerably reduces implementation risks associated with the development of 27 different national solutions and ensures a uniform level of digital functionality across the Union. Interoperability is instead only required with complementary Union digital infrastructures, notably IMI, the EUDI framework, digital credentials, the SDG and the OOTS. These interfaces are developed centrally by the Commission, ensuring consistent implementation and avoiding divergent national technical solutions.

The proposed solution is therefore not conceived as a new standalone platform but as a modular evolution of the existing digital infrastructure. It reuses established governance arrangements, user management, security architecture and administrative cooperation mechanisms while extending them to support the complete recognition workflow. It also builds on the experience gained through the European Professional Card, replacing its profession-specific digital procedure with a scalable solution covering all professions while maintaining compatibility with future developments in digital credentials and evidence exchange.

The initiative guarantees that digitalisation increases efficiency without creating new barriers to access. The resulting system combines a single European digital workflow with flexibility during implementation and coherence with the wider Union digital ecosystem.

Coherence with relevant tools and initiatives

The proposed digital solution has been designed to build on existing Union digital infrastructures rather than duplicate them. It reuses existing systems where these already provide the required functionality, adapts or extends them where necessary and creates synergies with other initiatives under the Skills Portability Initiative and the wider EU digital ecosystem.

The IMI system will continue to be the backbone for administrative cooperation. It already provides the secure infrastructure for administrative cooperation between competent authorities under Directive 2005/36/EC. Rather than establishing a parallel platform, the initiative extends the communication workflow in IMI with a complete workflow management system covering the entire recognition procedure. This approach allows the initiative to benefit from existing governance arrangements, user management, security architecture and operational experience while avoiding duplication of IT investments and limiting implementation risks.

The initiative is closely linked to SPI Action 1, which promotes the digitalisation of qualifications through the European Digital Identity (EUDI) framework for all professions. Action 2 enables the use of these digital credentials as the means for submitting qualifications in recognition procedures for regulated professions. Where available, applicants will also be able to reuse evidence retrieved through the Single Digital Gateway (SDG) and the Once-Only Technical System (OOTS), reducing the need to submit the same documents repeatedly. For professions benefiting from automatic recognition, the proposal goes a step further by requiring competent authorities both to issue and to accept digital qualifications without requesting further evidence or additional verification. The Commission will ensure the interoperability of the European Digital Recognition Solution with the EUDI framework, digital credentials, the SDG and the OOTS through centrally developed interfaces, guaranteeing consistent implementation across the Union while avoiding divergent national technical solutions. The two initiatives are therefore mutually reinforcing: Action 1 establishes the framework for issuing trusted digital credentials and other digital evidence, while Action 2 provides the operational recognition workflow through which these digital assets can be effectively used in regulated professions and, in particular, ensures that digital credentials achieve their full potential in the system of automatic recognition.

The initiative builds on the experience gained with the European Professional Card (EPC). The EPC demonstrated the benefits of digital handling of recognition procedures but remains limited to a small number of professions. The proposed solution replaces this profession-specific approach with a single, scalable workflow applicable across all professions covered by the Directive while reusing the operational experience, governance arrangements and technical lessons developed through the EPC.

The initiative also complements the Regulated Professions Database (RegProf), which remains the Union's authoritative source of information on regulated professions, competent authorities and recognition requirements. Information contained in RegProf will be restructured using the classifications of European Skills, Competences, Qualifications and Occupations (ESCO), and directly feed the applicant interface of the European Digital Recognition Solution, ensuring that applicants always access a single, reliable and up-to-date source of information when preparing their application. At the same time, the operation of the digital workflow will automatically generate and update information relevant to RegProf, including changes relating to competent authorities, regulated professions and statistical data on recognition procedures. The two systems will therefore be synchronised, improving the completeness, quality and timeliness of information while reducing duplicate reporting and manual updates by Member States.

Finally, the initiative creates important synergies with SPI Action 3 concerning the recognition of qualifications held by third-country nationals. By establishing a single European digital workflow linking applicants and competent authorities across all Member States, Action 2 creates a common procedural infrastructure that can also support the handling of recognition applications from third-country nationals. Rather than requiring separate digital solutions for different categories of applicants, the same workflow, case management tools, document handling and communication mechanisms can be used irrespective of whether the applicant is an EU citizen or a third-country national, while applying the respective legal rules governing each procedure. This reduces administrative fragmentation, avoids duplication of IT developments and facilitates the future implementation of Action 3 by providing an operational digital infrastructure on which it can build.

Taken together, these interactions ensure that the proposed digital solution complements rather than duplicates existing Union initiatives. It creates a coherent digital ecosystem in which existing infrastructures perform their respective functions while contributing to a seamless recognition procedure for applicants and competent authorities.

6.What are the impacts of the policy options?

This chapter examines the economic and social impacts of the proposed policy options. Section 6.1 analyses the direct cost impacts associated with each option. The direct impacts associated with each option comprise both benefits and costs. On the benefits side, these include administrative cost savings and monetised time savings for applicants, employers and competent authorities. On the costs side, they include implementation costs as well as additional administrative costs related to the expected increase in the volume of recognition applications and cases generated by the policy options. Administrative cost savings (under 6.1.1) include reductions in regulatory burdens for mobile professionals and, where they are involved in recognition procedures, their employers, as well as for competent authorities, while monetised time savings capture the direct microeconomic benefit for mobile professionals resulting from faster recognition procedures. 107  The implementation costs estimated in Section 6.1.2 consist primarily of the IT development costs associated with the three policy options, while Section 6.1.3 estimates costs related to the expected volume increases. 108  Broader economic impacts are presented qualitatively in section 6.2. 109  These include the impacts on the competitiveness of firms which are related to increased recruitment opportunities, mitigation of critical shortages, reduced attrition and turnover as well as macroeconomic impact such as improved allocative efficiency and asymmetric shock absorption. Section 6.3 analyses the social impacts, including employment opportunities, upward career mobility, combatting undeclared work, equal treatment, access to essential services. Together, these elements form the basis for the comparative assessment of the policy options in Chapter 7. 110  

6.1.Direct cost impacts

6.1.1.Administrative cost savings and monetised time savings 

The three policy options are expected to generate cost-savings for stakeholders through their effects on the compliance costs and administrative burden associated with recognition procedures under the PQD. The main stakeholders in this context are professionals seeking recognition and CAs 111 . For the purposes of cost estimation, recognition activity is treated as constant over the medium term, with an annual baseline volume of approximately 53 000 procedures per year.  112  The total administrative cost 113 is estimated by multiplying this number of procedures by the unit cost per procedure, which is EUR 330 per procedure for applicants and EUR 950 for CAs (combined unit cost of EUR 1 280 per procedure). 114 This gives a total annual cost of EUR 67.8 million. Given that the development phase is expected to take place in 2027–2028, the estimation assumes that the associated benefits begin to materialise from 2029 onwards.

Under PO1, non-binding measures are expected to generate modest reductions in administrative costs for both applicants and CAs. The effect is concentrated on the most information-sensitive cost components, where guidance-based simplification can have a direct impact. The savings attributable to each cost component reflect the specific mechanisms through which PO1 measures are expected to operate. 115 Cost-savings are estimated as percentage reductions in the baseline per-procedure burden and reduced by a realisation factor (i.e.: a percentage) reflecting expected partial achievement of savings. 116 For PO1, the expected administrative cost savings for applicants and CAs are estimated at EUR 81.5 per procedure. 117 At the SCM baseline of 53 000 procedures per year, 118 the aggregate annual administrative savings for applicants and competent authorities under PO1 are estimated at approximately EUR 4.3 million (recurrent, starting from 2029). 

In addition to these administrative cost savings for applicants and CAs, the direct cost impacts include monetised time savings for applicants: as recognition procedures become faster and waiting times decrease, applicants can more quickly enter the regulated profession for which they are qualified, translating into higher productivity and wages at the individual level. Applying the calculation method explained in Annex 4, 119 Option 1 is expected to yield for the applicants additional monetised time savings of EUR 86.2 million per year (recurrent, starting from 2029).

Beyond the costs incurred by applicants and competent authorities, recognition procedures also generate administrative costs for employers seeking to recruit professionals qualified in another Member State. These costs arise from the internal staff time devoted to supporting or managing recognition procedures, the payment of recognition fees where employers submit applications on behalf of prospective employees, and expenditure on external legal or consultancy services to navigate cross-border recognition requirements. The estimates are based on the SME Panel Survey conducted by the European Commission through the EU Survey portal in 2026 (159 SMEs across 18 EU and third countries). 120 Of the 159 respondents, 19 indicated that they directly manage recognition procedures on behalf of prospective employees, including the payment of the associated fees. This corresponds to approximately 12% of recognition procedures involving direct employer participation and forms the basis for the calculations. Respondents also estimated that a common EU digital recognition system could reduce employer-borne administrative costs by between 26% and 36%, depending on the cost category.  121 Applying the realisation factors used for each policy option (60% under PO1, 75% under PO2 and 95% under PO3) to this expected saving, and assuming approximately 6 360 employer-managed procedures annually with an average administrative cost of EUR 814 per recruitment, 122 results in expected aggregate annual reduction in employer-borne administrative costs of approximately EUR 1.0 million under PO1. 123

Thus, Option 1 would result in annual (recurrent, starting from 2029):

·administrative savings for applicants and competent authorities: EUR 4.3 million

·monetised time savings for applicants: EUR 86.2 million

·administrative savings for employers: 1.0 million

The cumulative present value of these direct cost savings over the period 2029–2040 is estimated at EUR 858.5 million, discounted to 2026 using a 3% discount rate. 124  

PO2 consists of binding legislative measures complemented by voluntary digital tools, which directly addresses the dominant cost drivers identified in the survey data and focus group evidence: translation and documentation proliferation, excessive CA staff time on document verification, and opaque fee. The binding character of the measures is expected to produce materially larger cost-savings. 125  For PO2, the expected administrative cost savings for applicants and CAs are estimated at EUR 243 per procedure. 126  At the baseline of 53 000 procedures per year, the aggregate annual saving under PO2 is estimated at approximately EUR 12.9 million administrative cost savings for applicats and competent authorities (recurrent, starting from 2029). Applying the calculation method explained in Annex 4, Option 2 is expected to yield additional monetised time savings of EUR 107.8 million per year to the applicants. 127  Similarly to Policy Option 1, there would also be administrative cost savings for employers. Applying the methodology explained above, these savings are estimated at EUR 1.2 million per year for PO2.

Thus, Option 2 would result in annual (recurrent, starting from 2029):

·administrative savings for applicants and competent authorities: EUR 12.9 million

·monetised time savings for applicants: EUR 107.8 million

·administrative savings for employers: 1.2 million

The cumulative present value of these direct cost savings over the period 2029–2040 is estimated at EUR 1 143.7 million, discounted to 2026 using a 3% discount rate.

Under PO3, a more comprehensive legislative revision is expected to produce the most comprehensive reduction in per-procedure costs. It substantially reduces, and in some cases eliminates, the translation and documentation burden, which is a dominant cost component, standardises CA processing workflows, and substantially reduces procedural discretion. The realisation factor of 95% reflects the mandatory character of the provisions, with very limited scope for national discretion following transposition. For PO3, the expected administrative cost savings for applicants and CAs are estimated at EUR 512.5 per procedure. 128 The savings attributable to each cost component reflect the comprehensive scope of PO3 mandatory measures. 129 At the SCM baseline of 53 000 procedures per year, the aggregate annual saving under PO3 is estimated at approximately EUR 27.2 million (recurrent, starting from 2029). Applying the calculation method explained in Annex 4, Option 3 is expected to yield additional monetised time savings of EUR 136.6 million per year to the applicants. In addition, there would also be administrative cost savings for employers. Applying the methodology explained above, these savings are estimated at EUR 1.5 million per year for PO3.

Thus, Option 3 would result in annual (recurrent, starting from 2029):

·administrative savings for applicants and competent authorities: EUR 27.2 million

·monetised time savings for applicants: EUR 136.6 million 130  

·administrative savings for employers: 1.5 million

The cumulative present value of these direct cost savings over the period 2029–2040 is estimated at EUR 1 550.9 million, discounted to 2026 using a 3% discount rate.

The table below shows the discounted cumulative benefits by policy option for the period 2029–2040, broken down into administrative cost savings for applicants and competent authorities, monetised time savings for applicants, and administrative cost savings for employers. All values are expressed as discounted present values.

***

Above, under the specific objective of making recognition processes faster, easier and less burdensome, a reference point was proposed consisting in a possible reduction of the overall cost of recognition procedures by 25%. The 25% simplification target used in EU Better Regulation discussions is treated here as an indicative reference point rather than as a binding target, in line with the analytical purpose of the assessment. 131 Considered against this reference: PO1 would deliver a comparatively limited annual reduction in the total system burden of approximately 7.8% (5.3/67.8 million EUR) relative to the annual baseline; PO2 would deliver an annual reduction in total system burden of approximately 20.8% (14.1/67.8 million EUR); and PO3 would deliver annual reduction in total system burden of approximately 42.3% (28.7/67.8 million EUR) relative to the annual baseline. 

6.1.2.Implementation costs

This section assesses the implementation costs 132 associated with the different policy options and identifies whether these costs would be borne by the Commission or by MS’ national administrations, including CAs. 133 Under all policy options, digital workflows would be implemented, but their deployment would vary: PO1 would rely on the voluntary use of the EU-level tool by MS; PO2 would introduce a mandatory workflow, with MS having the choice to implement the workflow on national level or to voluntarily use the EU-level tool; PO3 would require the use of a mandatory EU-level tool. In options 1 and 3, the Commission would set up and operate the workflow management system, while Member States would use it on a voluntary basis in option 1 and on a mandatory basis in option 3. As the procedure would run within the common EU system, interoperability with national systems would not be required. In option 2, by contrast, implementation would depend on both the Commission and Member States: the Commission would enable cross-border communication and statistics, while Member States would maintain national systems aligned with a common workflow. This option therefore requires substantial interoperability and carries higher risks of incomplete compliance, uneven implementation and delayed deployment.

In all three options, the Commission would cover the costs of developing and operating the European Digital Recognition System (EDRS) at EU level. The EDRS would include: a common digital workflow; state-of-the-art interfaces for applicants and competent authorities; AI-supported tools to streamline the handling of recognition applications; interoperability with key Commission systems, such as the SDG Once-Only Technical System (SDG-OOTS) and the European Digital Identity Wallet (EUDI Wallet); analytics and statistics dashboards; and integration with an enhanced Regulated Professions Database. One-off development costs, covering security, release, training and communication activities), are estimated at EUR 4.46 million and would be incurred equally in 2027 and 2028. Following the system’s launch at the end of 2028, annual operational costs, covering hosting, maintenance and user support, are estimated at EUR 1.09 million during a two-year stabilisation period (2029–2030) and EUR 0.65 million thereafter (2031–2040).

The identical costs in all three policy options would thus be:

·One-off implementation costs (split over 2 yrs): EUR 4.46 million

·Operation costs (years 1 & 2): EUR 1.09 million per year

·Operation costs (year 3 onwards): EUR 0.65 million per year

The total implementation cost for the 2027-2040 period would be EUR 13.12 million, or EUR 11.14 million, expressed in present value terms and discounted to 2026 at a rate of 3%.

Under policy option 2, additional costs would need to be borne by MS opting for national solutions (e.g., to improve interoperability with domestic systems). These are estimated to face one-off costs of EUR 2.89 million per MS (split over two years). Such costs would cover the adaptation and development of national systems, integration with EU shared services, EUDI verification and issuing features, and SDG-OOTS verification integration. Annual operational costs per national system are estimated to be EUR 0.29 million. Total costs for MS for the period 2027-2040 would depend on the uptake of the EU-level solution: EUR 0 if all MS use the EU-level solution; up to EUR 171.67 million if all develop national solutions; EUR 69.94 million in a realistic scenario where 11 MS implement national solutions. Over the period 2027–2040, the total cost is estimated at EUR 60.24 million in discounted present value terms, expressed in 2026 prices and applying a discount rate of 3%.

The total implementation costs for the 2027-2040 period would thus be: PO1 and 3: EUR 13.12 million (discounted at 3%: EUR 11.14 million); PO2 (realistic scenario): EUR 83.06 million (discounted at 3%: EUR 71.38 million).

6.1.3.Costs related to expected volume increases

On top of the IT implementation costs, one should also consider the costs related to the expected volume increases in recognition procedures (see footnote above). 134 Under PO1, the expected increase corresponds to approximately 2 650 additional procedures annually from 2029 onwards. This would entail additional costs of EUR 3.4 million annually from 2029 onwards and result in cumulative additional costs with a discounted (3%) present value of approximately EUR 31.9 million over the period 2029-2040 under PO1. Under PO2, the expected increase corresponds to approximately 4 770 additional procedures annually from 2029 onwards. This would entail additional costs of EUR 4.9 million annually from 2029 onwards and result in cumulative additional costs with a discounted present value of approximately EUR 46 million over the period 2029-2040 for PO2. Under Policy Option 3, the expected increase corresponds to approximately 6 625 additional procedures annually from 2029 onwards. This would entail additional costs of EUR 5.1 million annually from 2029 onwards and result in cumulative additional costs with a discounted present value of approximately EUR 47.9 million over the period 2029- 2040 for PO3. 135

6.2.Broader economic impacts 

In addition to the direct cost savings estimated in section 6.1., all three policy options are poised to generate broader economic benefits to the extent that they facilitate cross-border recognition of professional qualifications required to access regulated professions.

At firm-level, this results in increased recruitment opportunities relative to the baseline, enhancing their competitiveness and growth potential. Businesses can tap into a wider, geographically diverse pool of applicants whose qualifications are formally recognized by competent authorities. Whereas this effect benefits large corporations, they are particularly advantageous for SMEs, which often lack the administrative capacity to (help the applicant) navigate complex recognition procedures and are disproportionately impacted by acute labour shortages hampering growth. 136 According to a Eurobarometer survey, while 95% of SMEs report that finding employees with the right skills is a challenge for their business, only 14% have attempted to address these shortages by recruiting talent from other EU MS. When asked why they did not try to hire non-domestic talent, between 4% and 6% of companies specifically refer to difficulties in getting the professional qualification recognised. Of those that did try to hire workers from another MS, 6% to 7% pointed to such difficulties. 137 Facilitating cross-border recognition of qualifications addresses this concern, thus helping to reduce vacancy durations for critical roles and improve the structural match between the skills required for a position and the actual profiles of applicants. In its turn, better matching has a positive impact on employee productivity and retention. 138  

At macro-economic level, less costly and faster recognition procedures reduce “brain waste” and overqualification. By enabling qualified professionals to more easily access regulated occupations that match their specialized skills, they enhance the allocative efficiency and aggregate productivity of the workforce. 139 This increases potential GDP at a constant labour supply. The size of these impacts depends on the share of workers currently underemployed, the share employed in regulated professions, the degree of trust local employers have in foreign qualifications. It is also contingent on the relative importance of other legal and administrative barriers that hamper cross-border mobility. The potential magnitude of addressing these collective bottlenecks is illustrated by the European Value-Added Assessment on overcoming cross-border barriers. The study explicitly identifies the lengthy procedures for recognizing qualifications as a prominent barrier among many. According to its macroeconomic modelling, a realistic scenario achieving a 20% reduction across all covered cross-border barriers would unlock an estimated EUR 123 billion per year in gross value added (i.e. approximately 1% of total EU GVA) and help create over 1 million jobs throughout the affected EU land border regions. 140 In addition, swifter and less expensive cross-border recognition contribute positively to overall labour market resilience. By fostering greater geographic mobility, they help balance regional employment mismatches and absorb localized economic shocks.

Finally, the policy options also advance the digital transformation of recognition systems to varying degrees, improving efficiency, user-friendliness, and long-term digital capacity-building. 141 PO1 relies on voluntary digitalisation, promoting interoperability through guidance and best practices. While flexible, this approach risks uneven uptake, particularly in Member States with lower digital maturity. PO2 introduces mandatory digital workflows and interoperability standards, ensuring structured digitalisation across MS. However, implementation may pose challenges for authorities with limited digital infrastructure. PO3 goes further by mandating a unified EU-level digital system, guaranteeing full interoperability and standardisation. This reduces Member State implementation burdens but may limit integration with existing national systems.

All three policy options contribute positively to these firm-level and macroeconomic effects, though their impacts relative to the baseline vary. PO1 is expected to provide only marginal benefits, as its reliance on non-legislative, soft-law measures—such as voluntary peer reviews, common templates, and non-binding deadlines—leaves actual implementation entirely to the discretion of individual MS. In contrast, PO2 delivers a more pronounced impact; by establishing legally binding response deadlines and mandating interoperable digital credentials for automatically recognized professions, it introduces greater structure and predictability into cross-border data exchanges. Due to its stronger reliance on binding measures and by introducing a unified workflow, PO3 delivers the most substantial reductions in both applicant- and employer-borne costs while yielding the greatest time savings, even when taking into account the expected increase in the volume of applications under each of the policy options. It is therefore expected to also deliver the strongest positive impact on the various dimensions outlined.

6.3.Social impacts

At the individual level, faster and less costly recognition procedures compared to the baseline increase high-quality employment opportunities for mobile professionals. 142 By accelerating entry into formal, regulated occupations that match their true skill levels, they boost upward career mobility and enhance long-term income security. 143 The magnitude of these effects depends on a variety of factors, including the degree of occupational regulation in the host country, the transferability of country-specific human capital, the initial level of occupational downgrading, and local language proficiency.

Facilitating cross-border recognition ensures that mobile citizens can practice their profession based purely on merit, regardless of their Member State of origin. By removing these administrative and regulatory barriers, it secures the fundamental freedoms of movement, 144 establishment, and service provision within the internal market while upholding the core principles of equal rights and non-discrimination.

Increased mobility of professionals holding qualifications giving access to regulated professions may also strengthen the resilience and accessibility of essential public services, such as healthcare and education. 145 While nearly every Member State suffers from healthcare workforce shortages, these challenges are not uniformly distributed within the EU or within national borders, 146 reflecting different demographic, health socio-economic characteristics of populations, as well as diversity of health and long-term care policies in place at local and national levels. EU-wide and national averages frequently mask acute cross-country and regional disparities, with particularly urban centres attracting talent and rural, peripheral, and border regions facing severe shortages. As emphasised in a 2021 study by the JRC, such territorial imbalances confirm the need for a territorial approach in workforce planning exercises. 147 Facilitating cross-border mobility allows vulnerable regions to directly access and draw upon the wider Single Market talent pool, effectively stabilizing local social infrastructure where it is needed most. 148

All three policy options contribute positively to these micro- and macro-social effects, albeit to varying degrees depending on the nature of the regulatory intervention. PO1 is expected to yield only marginal social benefits as it operates through non-enforceable, soft-law instruments. Policy Option 2 delivers an intermediate impact as it introduces greater predictability into cross-border data exchanges and shortens timelines through binding deadlines. As demonstrated above, PO3 delivers the most substantial reductions in both applicant-borne barriers and integration timelines. It is therefore expected to deliver the strongest positive impact across all social dimensions outlined, most effectively translating administrative simplification into tangible social improvement.

The impacts of the initiative are expected to vary across MS and are unlikely to be distributed evenly across the Single Market. Both implementation costs and the magnitude of the expected economic and social benefits will depend on a number of structural and administrative factors, including the extent and sectoral composition of professional regulation, the volume of intra-EU mobility involving regulated professions, the organisation and performance of recognition procedures, including fees and processing times, and the degree of digital maturity of public administrations and recognition systems. These factors influence both the scale of the effort required to implement the proposed measures and the extent to which MS may benefit from simpler, faster and more digital recognition procedures. The main drivers of these differentiated impacts are examined in more detail in Annex 8. The diverging territorial impact reflects the diversity of national regulatory and administrative systems that the PQD is designed to accommodate. Facilitating recognition across such diverse systems lies at the heart of the mutual recognition framework established by the PQD. The initiative seeks to strengthen common pathways, interoperability and administrative cooperation within this diverse landscape, thereby supporting the functioning of the Single Market.

6.4.Summary overview of impacts 

The table below summarises the above impacts of the three policy options, including impacts assessed quantitatively and impacts described qualitatively.

7.How do the options compare?

This section evaluates the relative performance of each policy option by assessing: (i) their effectiveness in achieving the three specific objectives of the initiative; (ii) their efficiency in terms of the balance between savings and costs and their capacity to reduce inefficiencies in recognition procedures; and (iii) their coherence, namely the extent to which measures remain consistent with broader EU policy objectives, and contribute to a more coherent recognition system across the EU. The options are scored on a scale ranging from ‘-/+’ to ‘---/+++’ relative to the baseline. A single ‘-/+’ indicates a limited effect, while ‘--/++’ and ‘---/+++’ indicate a moderate and significant effect respectively. 149

7.1.Effectiveness

The effectiveness of the policy options is assessed against the three specific objectives of the initiative. For SO1, the comparison focuses on the extent to which the policy options improve the clarity, accessibility and user-friendliness of information, ensure greater consistency between national and EU-level information sources, and reduce incomplete applications and unnecessary exchanges between applicants and CAs during the preparation and submission of applications. For SO2, the assessment considers the extent to which the policy options increase digitalisation, reduce administrative burden and simplify procedures. For SO3 the comparison examines improvements in the timeliness and quality of administrative cooperation, the use of interoperable digital tools, and the consistency of implementation across MS. 150  

PO1 remains closest to the baseline, relying exclusively on non-legislative measures to promote a more consistent interpretation and application of the existing provisions without amending them (+). PO2 introduces targeted legislative amendments limited to those necessary to support interoperability and the digitalisation of procedures across MS, complemented by non-legislative measures (++). PO3 goes further by introducing a broader set of legislative changes and supporting them with operational tools designed to promote consistent implementation across MS (+++). As a result, the expected effectiveness increases progressively from PO1 to PO3. 151

7.2.Efficiency

The assessment of efficiency examines two aspects. First, it considers the relationship between the expected benefits and costs of each option, as presented in Section 6.1. Second, it assesses improvements to the efficiency of recognition procedures as such. 152  

Compared to the baseline, PO1 generates the lowest benefits but also entails low costs (++). PO2 delivers greater benefits, but also requires higher implementation costs (+). PO3 is expected to generate the highest ratio benefits/costs compared to the baseline (+++). As regards the efficiency of recognition procedures as such, PO1 remains closest to the baseline and is therefore expected to deliver only limited improvements (+). PO2 introduces targeted procedural changes that improve efficiency in specific areas. However, as MS would need to adapt solutions individually, implementation may remain uneven, limiting efficiency gains (++). PO3 goes furthest by combining more comprehensive legislative changes with supporting tools that facilitate implementation and administrative cooperation. Although achieving these efficiency gains would entail certain administrative burdens and obligations, these are expected to be offset in both the short and longer term (+++).

7.3.Coherence

The assessment of coherence examines: first, the coherence of the policy options with other relevant EU initiatives and broader Union objectives, including digitalisation, interoperability, administrative simplification, labour mobility and the functioning of the Single Market, and, second, the extent to which each policy option contributes to a more aligned, coordinated and integrated recognition system across MS, including through greater consistency between national systems, stronger interoperability of tools and procedures, and more coherent cooperation between CAs and the Commission.

Compared to the baseline, policy options differ in the extent to which they support broader EU objectives, notably simplification, digitalisation and administrative cooperation. PO1 is expected to make only a limited contribution through encouraging a more convergent interpretation and application of the existing framework (+). PO2 contributes more directly to these objectives through targeted measures supporting interoperability and information exchange (++). PO3 provides the strongest support by promoting a comprehensive digital and simplified approach to recognition procedures and administrative cooperation (+++).

As explained above under 5.2.3, the preferred option is coherent with the Union's broader digital policy framework because it builds on existing EU instruments rather than creating a parallel system. It is designed as a modular extension of the IMI system, reusing its governance, user base and administrative cooperation processes while extending its functionality to support the complete recognition workflow across all regulated professions. It also builds on the experience gained through the EPC, replacing its profession-specific approach with a single, scalable solution applicable across professions. At the same time, the proposal creates synergies with the EUDI Wallet, digital credentials under the SPI, and the SDG-OOTS. These tools are integrated where available, but their use is introduced progressively and without creating dependencies that could delay implementation. Where digital building blocks are not yet fully deployed, applicants will continue to be able to submit evidence themselves, authorities will continue to exchange information through IMI, and paper credentials will remain valid. This phased and interoperable approach ensures coherence with the Union's digital agenda while remaining proportionate and operationally realistic, avoiding duplication of existing systems and ensuring that implementation does not depend on the simultaneous maturity of all related initiatives.

The options also differ in their ability to increase coherence across recognition systems in the EU. PO1 is expected to bring only limited improvements compared to the baseline (+). PO2 would strengthen coherence by introducing common interoperability requirements and improving exchanges between CAs (++). PO3 is expected to have the greatest impact, as the European Digital Recognition System would support a more consistent implementation of recognition procedures across MS and enhance coherence throughout the system (+++).

7.4.Comparative overview 

The table below presents an overview of the comparison of the policy options on the basis of the criteria of effectiveness, efficiency and coherence. 154 As shown below, PO3 scores highest overall across these criteria. The assessment of proportionality also confirms that all three policy options would remain proportionate, each within the scope and level of intervention envisaged.

8.Preferred option

8.1.Option 3: Unified EU workflow and enhanced enforcement 

From the ranking and comparison of POs, PO3 stands as more effective, efficient and coherent than PO2 and PO1. PO3 comprises the most comprehensive set of binding legislative measures, combined with enforcement tools, and is therefore expected to deliver the objectives of the initiative in the most effective manner. As regards efficiency, PO3 is expected to generate the highest cost savings while keeping implementation costs much lower. It is designed as the most far-reaching simplification option and is estimated to alleviate around 40% of the burden currently associated with recognition procedures. Overall, it is expected to deliver cumulative cost savings of approximately EUR 1.6 billion by 2040. By centralising European digital resources and solutions, the approach ensures that key development costs are incurred only once at EU level, rather than separately by all 27 MS. In this way, it helps keep the main implementation costs linked to the creation of the European Digital Recognition System as low as possible. As regards coherence, this option ensures the strongest mutual reinforcement between measures, while also providing the highest level of alignment with broader EU initiatives and priorities on digitalisation, simplification, portability of skills, and the deepening and more effective functioning of the Single Market.

In terms of EU added value, the preferred PO3 delivers the greatest benefits through the establishment of the European Digital Recognition System as a common framework for recognition procedures across the Union. A single EU framework avoids duplication of investments, reduces fragmentation, promotes interoperability and generates economies of scale, while ensuring a more consistent and efficient recognition process across Member States. The preferred option complies with the principle of proportionality, as it does not go beyond what is necessary to achieve the objectives pursued. While the proposal introduces targeted amendments to Directive 2005/36/EC to address persistent shortcomings identified through its implementation, these measures are limited to improving the procedural functioning of the recognition framework, including the provision of information, the organisation of recognition procedures, administrative cooperation and the use of interoperable digital tools. The proposal does not harmonise the substantive rules governing regulated professions or the conditions for the recognition of professional qualifications. Member States remain fully responsible for regulating professions, determining qualification requirements, assessing applications and taking recognition decisions. The preferred option provides the most effective response to the identified problems while maintaining an appropriate balance between the expected benefits and the implementation effort required. Although it entails a greater degree of intervention than the alternative options, this is justified by the scale and persistence of the identified shortcomings and remains confined to procedural aspects of the framework, fully respecting Member States' competences over substantive recognition decisions.

As regards practical implementation, challenges may arise, but these are expected to be manageable, as the preferred option has been specifically designed to overcome the principal shortcomings of the current framework. As explained above, the identified problem drivers include both issues of design and issues of implementation, with special focus on the former.

Design issues arise where the current Directive misses common elements that are instrumental for the effective functioning of the recognition system and where the existing measures do not guarantee that the recognition procedures will fully benefit from technological progress and digital developments. Accordingly, the preferred option addresses design issues by completing the architecture of the PQD with common elements that are currently missing. The cornerstone of this approach is the European Digital Recognition Solution, which establishes a mandatory common digital workflow for recognition procedures across the Union. By replacing fragmented national solutions with a single interoperable system spanning the entire recognition procedure, from the preparation of applications to the issuance of recognition decisions, the preferred option streamlines workflows, reduces incomplete applications and repetitive exchanges, limits unnecessary procedural iterations and duplication of work, creates economies of scale and provides a common operational framework for competent authorities. The system will be developed and financed by the Commission, thereby reducing implementation costs for Member States while supporting authorities with AI-assisted functionalities (e.g. automated translation with confidence score) throughout the recognition process. 155 The preferred provides authorities with common tools and infrastructure rather than relying solely on national solutions. The European Digital Recognition Solution reduces administrative burdens and manual processing, allowing scarce administrative resources to be used more efficiently. The preferred option further strengthens the design of the framework by integrating into the recognition process interoperable digital credentials for qualifications under the automatic system. It establishes that these credentials constitute trusted evidence of the qualifications they certify, thereby limiting the possibility for competent authorities to request additional documentation and reinforcing trust within the automatic recognition system.

On the other hand, the preferred option strengthens the implementation of the existing legal framework by making its requirements clearer, more operational and easier to apply consistently across Member States 156 . It specifies in greater detail the information that Member States must provide on recognition procedures and ensures that this information is kept up to date through interoperability with the Regulated Professions Database. It clarifies which documents may be requested, establishes common principles governing recognition fees and introduces binding deadlines for the individual stages of recognition procedures as well as for administrative cooperation between competent authorities. By translating general obligations into more operational rules, these measures reduce uncertainty and facilitate more uniform implementation across the Union.

The preferred option further reinforces implementation through supporting measures. Regular training for competent authorities and a more structured framework for cooperation within the Group of Coordinators on Professional Qualifications will help competent authorities apply the Directive more consistently and identify implementation challenges at an earlier stage. The annual work programme of the Group of Coordinators 157 and its subgroups will provide a more systematic framework for monitoring implementation, exchanging good practices and preparing future developments of the recognition system. Additional mitigation measures could include transitional implementation periods, targeted capacity-building support, EU financial support for digital transformation where appropriate, and the progressive deployment of interoperable digital tools.

Taken together, the preferred option addresses both the structural and the practical causes of the identified problems. By introducing common elements that are currently missing from the Directive while making existing rules more precise and providing competent authorities with better tools, clearer rules, more structured procedures and stronger support, it is expected to improve the consistency, efficiency and reliability of the implementation of the Professional Qualifications Directive.

The transition towards a more digital and, under PO3, largely “digital-only” recognition environment may create risks of digital exclusion for certain categories of applicants, including older professionals or applicants with limited digital skills or access to digital infrastructure. While the initiative aims to simplify and accelerate procedures, the move towards digital procedures would create obligations for CAs rather than applicants. Applicants would remain free to submit supporting documents in paper form. However, those choosing to submit documents digitally would benefit from faster processing and reduced administrative. Where applicants are unable to create or submit a digital application themselves, CA could provide assistance and, where necessary, create the digital application on their behalf. Similarly, the introduction of binding deadlines would not create additional obligations for applicants. These deadlines would apply to CAs and their cooperation with each other, ensuring that procedures are completed more quickly and predictably for the benefit of applicants. The Commission would support implementation through guidance and training for CAs using the digital tools, while applicants would benefit from digital guidance tools such as pilot AI chatbots. The gradual implementation timeline, including the transposition period for MS and the time foreseen for the development of the European Digital Recognition System by the Commission, would provide sufficient time for MS, CAs and the Commission to prepare, coordinate and put the necessary support arrangements in place.

Moreover, stakeholders may express concerns that a greater reliance on digital tools could increase digital security and reliability risks. However, the initiative is expected to mitigate rather than exacerbate these risks. The use of verifiable digital credentials would make documents significantly more secure and more difficult to forge than paper-based documents, thereby increasing the reliability of the information exchanged in recognition procedures and strengthening trust among competent authorities. Furthermore, as artificial intelligence is increasingly being used in administrative processes, embedding AI-assisted functionalities within a common European framework would help ensure their transparent, coordinated and consistent use across MS. This would reduce the risks associated with fragmented national approaches, divergent outcomes and inconsistent quality standards, while promoting greater legal certainty, reliability and mutual trust in recognition procedures.

The implementation of the preferred option will require efforts from Member States and competent authorities, particularly to adapt existing procedures, working methods and digital systems. Some challenges may be greater for authorities with more limited administrative capacity or lower levels of digital maturity. 158 Nevertheless, we expect that these challenges will be manageable and that the authorities concerned will be broadly supportive of the proposed measures. The preferred option was designed on the basis of stakeholder feedback and is composed primarily of measures that national coordinators and competent authorities—the actors responsible for implementing the Directive—identified as among the most effective responses to the problems encountered in practice. 159 These results provide confidence that, although implementation will require adaptation and sustained effort, the preferred option is closely aligned with the practical needs and assessments of the authorities that will be responsible for applying it. In addition, the use of a common EU-level solution will reduce the need for Member States to develop and maintain separate national systems, thereby limiting national implementation costs and technical burdens while ensuring interoperability and a more consistent approach across the Union.

8.2.REFIT (simplification and improved efficiency)

The initiative is expected to contribute significantly to simplification and efficiency by directly addressing procedural complexities and inefficiencies identified as part of the problem definition. The measures proposed under the initiative are specifically designed to reduce these inefficiencies. By definition, measures such as reducing paper-based procedures, promoting interoperable digital credentials, reducing documentary requirements, accelerating exchanges between CAs and strengthening digital workflows are expected to simplify procedures, reduce waiting times and lower administrative and compliance costs. More complete and standardised information is expected to reduce the number of incomplete or incorrect applications and limit the need for clarification exchanges. This would reduce the time and effort required for applicants to understand requirements and prepare applications, while reducing rework associated with incomplete applications for CAs and improving processing workflows. For professionals, simplified and standardised procedures, together with the reduction and standardisation of documentation requirements and clearer and more predictable procedures, are expected to reduce both the time and costs associated with preparing and submitting applications, as well as broader compliance costs linked to recognition procedures. 160 The combination of harmonised procedures, mandatory digital workflows and fully digital processes is also expected to significantly reduce administrative effort per case and streamline case handling. More structured and predictable cooperation mechanisms are expected to reduce repeated exchanges, incomplete requests and processing delays. 161  For employers, more efficient and predictable recognition procedures are expected to facilitate faster recruitment processes, improve workforce planning and reduce delays in accessing qualified professionals, particularly in sectors facing labour shortages. Unlike more voluntary approaches, PO3 ensures uniform application and maximises efficiency gains through mandatory and integrated measures across the Union. At the same time, these expected simplification and efficiency gains are accompanied by significant upfront implementation costs. The introduction of harmonised systems, digital workflows and fully digital processes will require investment in IT systems and infrastructure, staff training and organisational adjustments. As a result, PO3 may initially lead to increased administrative costs during the transition phase. Over time, however, these costs are expected to be offset by efficiency gains and reductions in administrative effort per case, leading to a more coherent, predictable and efficient recognition system across the Union.

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

This initiative falls within the scope of the One-In-One-Out (OIOO) approach as it constitutes a revision of an existing EU instrument (Directive 2005/36/EC). PO3 contributes to the administrative burden reduction target by delivering aggregate annual administrative cost savings of approximately EUR 27.2 million, corresponding to a reduction of around 40% of the EUR 67.8 million baseline annual administrative burden. The main instrument carrying this reduction is the harmonisation and digitalisation of recognition procedures. The full quantification is developed above under Section 6.1 and also summarised below in Table III in Annex III.

9.How will actual impacts be monitored and evaluated?

Monitoring would focus on indicators measuring the extent to which the initiative succeeds in simplifying and making less costly and burdensome the preparation and processing of recognition applications, including cooperation between CAs. The Commission would carry out such monitoring in close cooperation with national coordinators and CAs in the MS.

Monitoring would rely on two sources. First, MS would provide information through national reporting coordinated by the national coordinators designated under the PQD. Such reporting would take place every two years and would cover indicators that cannot be automatically generated through digital systems. Second, data would be retrieved annually from the digital tools supporting the implementation of the initiative, including the European Digital Recognition System and other relevant systems and databases.

For monitoring purposes, 2029 would constitute the baseline year, as this is the first year in which the benefits of the initiative are expected to start materialising following the deployment of the European Digital Recognition System during 2027 and 2028. To establish a robust pre-implementation benchmark, a first collection of monitoring data would take place in 2028. A second wave of data collection would then take place in 2029 for indicators to be collected annually and in 2030 for indicators subject to biennial reporting, allowing an initial comparison between the situation before and after implementation. This approach would ensure the availability of meaningful evidence on the effects of the initiative and support a comprehensive evaluation approximately five years after the expiry of the transposition deadline.

Progress towards Specific Objective 1 will be monitored through indicators measuring the completeness and consistency of information provided on regulation of professions and recognition of qualifications, the share of incomplete or incorrectly prepared applications attributable to information gaps, and user satisfaction with the clarity and accessibility of information. Progress towards Specific Objective 2 will be monitored through indicators measuring the average processing time of recognition procedures, the average number of documents, translations and certifications requested per application, the administrative effort required to process an application, and the share of applications completed within the prescribed deadlines. Progress towards Specific Objective 3 will be monitored through indicators measuring the average response time to administrative cooperation requests, the average number of information requests and confirmation exchanges per recognition case, and the satisfaction of competent authorities with the quality and usefulness of the responses received.

A more detailed presentation of the monitoring indicators, sources and collection methods is provided in Annex 16.

Annex 1: Procedural information

1. Lead DG, Decide Planning/CWP references

DG for Employment, Social Affairs and Inclusion (DG EMPL). PLAN/2025/2645: Fair labour mobility package / Skills Portability 2: modernise and expand recognition processes for regulated professions - Potential measures to facilitate, modernise and expand recognition processes for EU citizens to access regulated professions, action under the Skills Portability Initiative. Commission work programme 2026, Supporting people, strengthening our societies and our social model - 25: Skills and fair labour mobility – Fair labour mobility package

2. Organisation and timing

The consultation and evidence-gathering activities build on earlier work carried out in the context of the 2020–2024 implementation report on Directive 2005/36/EC and were further developed through more recent exercises conducted under the Skills Portability Initiative. These included the public consultation and call for evidence carried out between November 2025 and February 2026, complemented by desk research and data analysis undertaken by DG EMPL and by the contractor responsible for preparing the study supporting the present impact assessment.

The contract for the study supporting the impact assessment of Directive 2005/36/EC started in October 2025 and had a duration of fifteen months. The contractor submitted the final report supporting the impact assessment, focusing on the SPI-related aspects of the Directive, in May 2026 for the purposes of the scrutiny process by the Regulatory Scrutiny Board.

An Inter-service Steering Group (ISG) was established by the Secretariat-General to support the preparation of the initiative as part of the broader SPI package. Representatives from the following Directorates-General and services participated in the ISG: EAC, ECFIN, ENV, GROW, HOME, REGIO, RTD, SANTE, TRADE, the Secretariat-General and the Legal Service.

3. Consultation of the RSB

The draft IA was submitted to the Regulatory Scrutiny Board (RSB) on 17 June and discussed at a hearing on 15 July, following the submission of written replies to the RSB checklist and technical comments received in advance of the hearing. The RSB subsequently issued a positive opinion with reservations. The IA was subsequently revised to address the recommendations set out in the RSB opinion, while also taking into account the technical comments provided by the Board in the course of the scrutiny process. The table below summarises the RSB’s main recommendations and the corresponding updates made to the IA to address them.

4. Evidence, sources and quality

The impact assessment draws on multiple sources of evidence and expertise, as detailed in Annexes 2, 4 and 17 to the present report. These include, in particular, evidence collected by the Commission services in the context of the 2020–2024 implementation report on Directive 2005/36/EC, as well as consultation and research activities carried out by the contractor responsible for the supporting study. The Commission Expert Group on the Recognition of Professional Qualifications was closely involved throughout the consultation process.

Annex 2: Stakeholder consultation

The preparation of this initiative was supported by a broad evidence-gathering and consultation process. This included data collected in the context of the implementation report on Directive 2005/36/EC, targeted consultation activities carried out by DG EMPL, the public consultation launched by the Commission, as well as additional stakeholder consultation activities conducted by the external contractor supporting this IA.

1. Analysis of data collected for the report on the implementation of the PQD

The drafting of this IA has benefited extensively from data collected by DG EMPL, including in cooperation with DG GROW, in the context of the preparation of the report on the implementation of the PQD covering the years 2020–2024. The report and the accompanying Staff Working Document were published in February 2026 162 and have been extensively referenced above. Those documents describe in detail how stakeholders’ views contributed to identifying the main shortcomings in the implementation of the PQD and, subsequently, to shaping the present initiative.

2. Targeted consultations carried out in the context of the SPI

In parallel to the work carried out with the contractor and the use of data and findings from the implementation report to shape the problem analysis, DG EMPL also conducted targeted stakeholder consultation activities as shown below. These proved particularly useful in validating the different dimensions of the problem and gathering views and suggestions from professionals and public authorities in the MS regarding possible solutions.

3. SPI public consultation (questionnaire and call for evidence)

The public consultation on the SPI, conducted between December 2025 and February 2026, gathered views from a wide range of stakeholders on the portability of skills and qualifications within the EU. The consultation aimed to identify the main challenges faced by individuals and employers when using qualifications across borders, collect evidence on experiences with recognition procedures and skills validation (including their effectiveness and usability), and explore key obstacles to labour mobility linked to recognition issues. It also sought to identify opportunities to improve mobility through more effective recognition, validation and use of skills.

A total of responses were received from diverse stakeholder groups, including EU citizens (336 – of whom 66 had undergone recognition of their professional qualifications in another Member State), non-EU citizens (143), public authorities (81), academic and research institutions (44), NGOs (43), business associations (41), companies (29), trade unions (11) and other stakeholders (56). The input collected through this consultation has informed the problem definition, supported the development of policy options, and contributed to the assessment of impacts, in particular with regard to targeted aspects of the Professional Qualifications Directive. The key points emerging from the public consultation are summarised below. They broadly confirm the findings identified through the other stakeholder consultation activities:

·Persistent barriers to skills portability. Respondents consistently identify lengthy, complex and costly recognition procedures as one of the most significant obstacle to skills portability in the EU (524 out of 785 total respondents).

·Fragmented and unclear information environment to guide recognition processes. Information on recognition requirements is dispersed across multiple national and EU sources, with no single authoritative entry point. EU citizens report unclear, incomplete or missing information on procedures, CA, documentation requirements and expected outcomes (36 out of 157 respondents to the relevant question), increasing the likelihood of delays and failed applications.

·Insufficient access to guidance and support during recognition procedures. Only half of applicants report having had access to support during recognition procedures (33 our of 66 respondents – EU citizens having applied for recognition of professional qualifications), while support is often considered limited or ineffective. The absence of coordinated guidance and case management exacerbates administrative burden, particularly for individual applicants, SMEs and early‑career professionals.

·Excessive timeframes and high, uneven costs. Recognition procedures frequently last months and, in some cases, years, thus often exceeding statutory deadlines (cf. Chapter 2 above). Applicants face significant and unpredictable costs related to fees, translations and certifications, creating strong deterrents to mobility and reinforcing inequalities in access to recognition (cf. Chapter 2 above).

·Need for better integration and interoperability. Stakeholders overwhelmingly identify the creation of an EU‑wide interoperable system for qualifications and skills as the main solution to improve skills portability (404 out of 642 respondents). The priority is not to multiply tools, but to ensure interoperability, reuse and trust across existing EU and national systems.

·Digital credentials as a priority. Verifiable digital credentials are widely seen as a key enabler of skills portability, provided they are trusted, legally meaningful and integrated into established recognition frameworks, notably the PQD (they are considered very important by 264 and important by 121 out of 449 respondents). Digitalisation is expected to support faster verification, reduced duplication and greater transparency, but not to replace substantive assessment by CA, especially in regulated professions.

·Simplification and digitalisation of recognition procedures. Respondents (n=642) prioritise practical digital solutions that streamline administrative procedures, including single online portals for the submission and tracking of applications (469 respondents), automated document verification (372 respondents), certified and automated translations (372 respondents), and digital pre-screening to determine whether recognition is required (212 respondents). These solutions aim to reduce duplication, delays and uncertainty for both applicants and employers.

·The recognition process can have significant consequences for the professional opportunities and mobility of applicants. Among the 66 EU citizens who had undergone a recognition procedure, 17 respondents reported accepting a job below their qualification level, indicating a skills mismatch. Thirteen respondents stated that the process encouraged them to resume studies or training in order to meet recognition requirements. 12 respondents obtained a job opportunity matching or exceeding their qualification level, while another 12 respondents reported having missed a job opportunity as a result of the recognition process. 11 respondents indicated that they had started working in a different field, and 10 respondents reported delays in starting a new job. In addition, 9 respondents stated that the outcome discouraged them from moving to or applying for a job opportunity in another country, while 2 respondents indicated that the process ultimately led them to leave the EU and migrate elsewhere. Stakeholders consistently associate delayed, partial or failed recognition with significant skills waste, as professionals are compelled to accept underqualified roles or work outside their field while procedures are pending, even in sectors experiencing acute labour shortages.

The call for evidence feeding into the public consultation confirms that qualification recognition systems in the EU remain fragmented, lengthy and unpredictable, generating significant barriers to labour mobility and skills portability. Stakeholders consistently report that limited trust in foreign qualifications, divergent scopes of practice across MS, and assessment practices centred on diplomas constrain both employer recruitment decisions and individual career progression. These challenges translate into delayed labour market entry, skills waste, downgraded employment outcomes and missed job opportunities, with disproportionate effects on SMEs, early‑career professionals and sectors characterised by high regulatory or safety requirements. Employers, in particular, underline legal and operational risks linked to uncertainty over professional status, good standing and timelines, which discourages cross‑border hiring even in contexts of labour shortages.

Evidence also highlights persistent structural weaknesses in recognition procedures themselves, which frequently exceed PQD deadlines and impose high direct and indirect costs related to fees, translations, compensatory measures and income loss during prolonged procedures. Fragmented information landscapes and the lack of a single authoritative entry point further exacerbate uncertainty for applicants and employers, leading to inappropriate applications, procedural duplication and administrative fatigue. These shortcomings undermine confidence in the practical enforceability of free movement rights and generate spill‑over effects for employers through delayed onboarding, disrupted workforce planning and increased reliance on interim labour solutions.

Finally, contributors show strong support for EU‑level action to address these challenges, provided it builds on existing legal and administrative frameworks rather than creating parallel mechanisms. Stakeholders broadly endorse better integration, interoperability and operational use of EU transparency tools such as the EQF, Europass, ESCO and the SDG, alongside clearer, more intelligible qualification information. While digital and verifiable credentials are viewed positively in principle, their uptake is conditional on clear legal value, robust governance, and full embedding into established recognition procedures. Across stakeholder groups, there is a consistent call for proportionate, profession‑specific solutions that improve predictability and trust while safeguarding professional standards, liability frameworks and public interest objectives.

4. Stakeholder consultations carried out for the supporting study

As part of the evidence-gathering for this impact assessment, a range of targeted consultation activities was carried out by the contractor to collect additional input from key stakeholders. These activities aimed to refine the problem definition, inform the design of policy measures, and assess their potential impacts. They comprised strategic interviews, a consultation workshop, focus groups, and surveys, as outlined below.

Strategic interviews were conducted to refine the scope of the analysis and gather additional evidence on the SPI, the PQD, key issues affecting recognition procedures, and possible adjustments suggested by stakeholders. In total, 8 interviews were carried out with 10 Commission staff members from DG EMPL, DG GROW and DG SANTE. A consultation workshop was organised to discuss and further develop the problem definition. The workshop took place in February 2026 and brought together 39 participants, including members of the GoC and National ACs. Two focus groups were organised to collect stakeholder feedback on the expected impacts of the preliminary policy measures designed to address the identified problems in recognition processes. The first focus group took place in February 2026 with EU-level representative organisations of the seven sectoral professions benefiting from automatic recognition based on minimum training requirements. The second focus group was held in March 2026 with members of the GoC and covered the same set of topics. Finally, two surveys were conducted to collect evidence on (i) the costs incurred during recognition procedures and (ii) the potential benefits of digitalisation. One survey targeted national CA responsible for recognition processes in the seven sectoral professions under automatic recognition and was disseminated through the GoC and direct outreach. The second survey targeted EU citizens holding professional qualifications who are currently seeking, or have previously sought, recognition for one of these professions; it was circulated through professional representative organisations participating in the consultation process.

Consultation workshop and focus groups

The workshop, involving 39 participants, confirmed that the proposed problem definition broadly reflects national realities, where significant divergences persist. Divergences are particularly noticeable between well-functioning automatic recognition systems and more burdensome general systems. The main structural constraints identified were insufficient administrative capacity, excessive verification requirements (reported by 5 participants), weak administrative cooperation (delayed or missing replies from competent authorities were reported by 12 participants), and underuse or ineffective use of IMI and EPC tools (excessive use of IMI alerts was reported by 7 participants), often compounded by delayed or missing responses from other authorities. Linked to the problems presented, participants stressed the lack of trust in foreign qualifications, especially in the general system, which drives over-checking and repeated requests for documentation. Participants highlighted persistent information gaps for applicants, notably regarding the competent authority to contact, required documentation, procedural steps, and compensation measures, despite partial progress through portals, assistance centres, and the Single Digital Gateway. Applications remain frequently incomplete (7 participants reported receiving complete and correct applications to a great extent, 18 to a certain extent, and 7 to a limited extent); incomplete applications are found especially in the general system, particularly where professions are regulated in one Member State but not in another, or where supporting documents (e.g. certificates of good standing or evidence of professional experience) are difficult or impossible to obtain. Digitalisation has advanced but remains uneven: processes are often only partially digital, document submission channels remain fragmented, and digitally signed certificates face interoperability barriers. Overall, the discussion pointed to the need to strengthen trust-based recognition, improve interoperability and usability of EU-level tools (IMI, RegProf, EPC), and reduce administrative burden through clearer rules, better data alignment, and more effective cooperation between competent authorities.

The two focus groups broadly confirmed that the main obstacles to the effective functioning of automatic recognition under the PQD are not so much rooted in the legal framework itself, but in shortcomings in its implementation. Participants from both professional organisations and CA consistently pointed to fragmented, incomplete, and poorly coordinated information available to applicants (24 of the 28 GoC members reported increased administrative workload due to information gaps “to a certain extent”), limited digitalisation of procedures, and uneven administrative capacity across MS as the primary drivers of delays, uncertainty, and additional costs for CAs. There was strong convergence on the need to improve the clarity, accessibility, and consistency of information requirements (a priority for 26 of the 28 GoC members), including documentation, timelines, and fees, while avoiding measures that could undermine professional standards or public interest objectives.

The discussions highlighted broad support for policy measures aimed at process efficiency, digitalisation, and stronger administrative cooperation. Digital-by-default procedures, better use of existing EU tools such as IMI and the Single Digital Gateway, proportional documentation requirements, and AI-assisted workflows were widely seen as having the greatest potential to reduce administrative burden and improve predictability, provided they support rather than replace professional judgment. By contrast, shortening statutory recognition deadlines were met with significant reservations, particularly from CA concerned about administrative capacity, overall process duration, and unintended redistribution of workloads, notably for third-country qualifications. Overall, participants considered that the effects of the proposed measures would be broadly beneficial (including a slight reduction of incomplete or incorrect applications, expected by 8 of the 28 GoC members), and a limited reduction of the duration of application procedures, expected by 3 of 21 professional organisations representatives). However, both groups stressed that expected benefits would materialise only gradually and subject to complementary conditions, including adequate resourcing, training, interoperability of systems, and effective national implementation. Both focus groups emphasised that improvements in recognition processes depend less on legislative change than on consistent application, mutual trust between authorities, and sustained investment in digital infrastructure and cooperation mechanisms.

Surveys with citizens and CA

Out of the 203 citizen surveyed, 48 provided relevant replies. Survey results indicate limited clarity of pre-application information. Only 12/48 respondents consider the information very clear, while 26/48 describe it as clear but point to inconsistencies across sources. 8/48 respondents finds the information difficult to understand.

Survey responses from citizens also confirm that recognition procedures are often lengthy. Most respondents report that the process took more than four months from application to decision (26/48 respondents), while only a small share experienced processing times between three and four months (5/48 respondents). Preparatory steps are also time-intensive: determining whether a profession is regulated requires weeks or months for a large share of respondents (21/48 respondents), while seeking professional advice entails similar timeframes (19/48 respondents). Identifying the CA requires significant effort for nearly one third of respondents. Regarding documentation, most citizens consider requirements proportionate to their purpose, either fully (18/48 respondents) or mostly (16/48 respondents). However, a non-negligible share perceives them as excessive (14/48 respondents).

CA largely confirm the proportionality of documentation requirements, with most considering them fully proportionate (52/82 respondents) or mostly proportionate (27 respondents), and only a marginal share viewing them as somewhat excessive (2 respondents). According to CA, delays in recognition procedures primarily stem from incomplete or incorrect documentation submitted by applicants (57/82). Additional sources of delay include late responses from other authorities (15/82) and the time required for authenticity checks (12/82), indicating that inefficiencies are closely linked to documentation quality and inter-authority coordination.

Staff effort in CA varies significantly depending on the activity to be carried out in the context of recognition procedures. Routine tasks, such as maintaining national portals or updating the RegProf, usually require fewer than 10 to 20 man-days per year, while responding to preliminary inquiries and issuing certificates often require between 20 and more than 50 man-days, and in some cases exceed 150 man-days. Core assessment activities, including equivalence assessment, document authenticity checks and drafting decisions, frequently require 30 or more man-days annually. Digitalising paper-based files continues to require substantial effort, indicating incomplete transition to fully digital workflows. In terms of staff needs to process recognition applications, CAs report significant variation: 21/82 indicate between one and two FTE, 15/82 indicate between two and five FTE, 14/82 indicate between five and ten FTE, 11/82 between one and 0,5 FTE, while 10/82 operate with less than 0,5 FTE. Financially, the most significant costs relate to the development and updating of electronic templates (around EUR 28 000 annually), followed by cybersecurity and data protection compliance (around EUR 14 000) and core IT infrastructure costs (around EUR 13-14 000). Phone and printing services entail moderate costs (around EUR 6-8 000), while expenditure on staff training remains comparatively low (around EUR 4 000). Additional costs not fully captured include legal fees, expert assessments and further IT or digitalisation expenses, in some cases amounting to hundreds or thousands of euros annually. Cooperation among CAs is mainly constrained by differences in national procedures or requirements (47/82), as well as delayed responses and lack of clear deadlines (36/82), highlighting structural barriers to timely cooperation.

Application costs are varied. Fees for certified translations and for notarisation, legalisation or apostille are incurred by a large majority of citizens (35/48 respondents). Other common costs include obtaining official documents from home country authorities (32/48 respondents), postal or courier services (33/48 respondents), identity verification (25/48 respondents) and application-related fees in the host country (30/48 respondents), although only a small share report fees specifically for submitting the application (2/48 respondents). Expenditure levels vary widely, from negligible amounts to several hundred euros, and in some cases thousands of euros, with translation costs frequently reported between EUR 100 and EUR 300 and sometimes exceeding EUR 500. Respondents also report additional costs not formally part of the procedure, such as language courses, exams and travel, which in some cases amount to several thousand euros and represent a significant barrier to access. Survey results indicate that costs and duration affect mobility decisions. While nearly half of respondents report that these factors did not prevent them from working in another MS (22/48 respondents), a substantial share experienced significant difficulties without abandoning mobility plans (19/48 respondents). 7/48 respondents postponed or abandoned mobility altogether, illustrating the deterrent effect of financial and administrative burdens on cross-border mobility.

From the citizens’ perspective, recognition procedures remain largely non-digital. A majority report that it is not possible to complete the process fully online (33/48 respondents). Key bottlenecks include document submission (27/48 respondents), identity verification (16/48 respondents), communication with CA, delivery of the final decision and in-person appointments (12 respondents each). Even payment of fees still involves non-digital steps for a significant share of respondents (10/48 respondents).

By contrast, CAs report higher levels of digitalisation. Just less than half indicate that the full recognition process can be partially conducted online (38/82), while a third report full digitalisation (29/82) and one sixth report no possibility to complete the process online (14/82). This discrepancy points to uneven implementation of digital tools across authorities. Despite limited realised savings, authorities identify substantial future potential of digitalisation tools and measures to aid recognition processes. The most consistently expected benefit is shorter recognition processes (44/82), particularly through faster document exchange and reduced duplication. Many also anticipate lower costs for applicants (e.g. fewer apostilles and certified copies) (40/82), though benefits for authorities themselves are perceived as more uncertain. Higher efficiency in terms of less staff needed is expected by 23/82 authorities. Respondents stress that digitalisation alone is insufficient: tangible gains depend on legal acceptance of fully digital procedures, interoperable and trusted EU level verification tools, and greater convergence of national practices. Without these enabling conditions, digitalisation risks changing the nature of work rather than reducing overall costs or workload.

Annex 3: Who is affected and how?

1. Practical implications of the initiative

The implementation of the preferred option would require significant practical action by both the Commission and the MS to ensure that the revised framework functions effectively in practice.

For the Commission

·Prepare and propose the legislative amendments necessary to introduce the measures under the preferred option.

·Monitor and support the implementation of the revised Directive using the usual enforcement tools available to the Commission and the application of lump-sum compensation.

·Facilitate exchanges of best practices, common understandings and operational coordination within the Group of Coordinators and its subgroups.

·Provide and maintain the EU-level digital system and AI-supported workflow tools supporting recognition procedures.

·Provide continuous technical support, operational guidance and training to national administrations using the new tools and systems.

For MS and CAs

·Transpose the revised Directive into national law and adopt the necessary implementing measures at national level.

·Ensure coordination between national coordinators and CAs responsible for recognition procedures.

·Instruct and support CAs on the practical implementation of the revised rules and procedures.

·Provide complete, accurate and regularly updated information on regulated professions and recognition requirements.

·Regularly provide updated statistics and cooperate effectively with the Commission and other MS.

·Use correctly and consistently the EU-supported system and AI-supported workflow made available for recognition procedures.

·Adapt internal workflows, administrative practices and, where necessary, IT infrastructure to support digital and AI-assisted procedures.

·Respect binding deadlines for recognition procedures and administrative cooperation requests.

·Respect obligations relating to lump-sum compensation mechanisms in cases of non-compliance with deadlines.

·Refrain from requesting unnecessary additional documents, translations or verifications where interoperable digital credentials are used.

·Respect harmonised rules on fees, procedural deadlines and appeal rights established under the revised Directive.

·Draw the attention of the Commission and other MS to shortcomings, implementation difficulties and areas requiring further attention or improvement in the practical application of the revised Directive.

2. Summary of costs and benefits

Source: Elaboration based on quantitative estimates drawn from citizens/professionals survey (n=48); CA survey (n=81); GoC Focus Group (4 March 2026); Scholz and Rohr (2026); ECA Special Report 2024-10; SWD(2026) 64 final. Aggregate estimates based on approximately 53.000 annual procedures (long-run SCM baseline).

Source: Working estimates developed in cooperation with the digital units of DG EMPL and DG GROW, SPI public consultation, CA survey (Q17).

1) Administrative burden reduction estimates derived from the SCM analysis using the EU Standard Cost Model (2) Applicant-borne savings and CA-borne savings estimated from component-level analysis. (3) Employer aggregate savings estimated; SME Panel Survey (2026) provides unit-level evidence (30% saving per cost category) but total population of employer-supported procedures is not precisely known. Source: SME Panel Survey (2026, n=159); CA survey (n=81).

3. Relevant sustainable development goals

The initiative is relevant to four of the United Nations Sustainable Development Goals, as summarised in Table IV below. The most directly relevant goals are SDG 8 (Decent Work and Economic Growth) and SDG 10 (Reduced Inequalities), which represent the primary impact channels of the initiative and reflect its core objective of removing barriers to labour market participation for qualified professionals exercising their right to free movement. SDG 4 (Quality Education) and SDG 17 (Partnerships for the Goals) are indirectly relevant through the initiative's effects on the recognition and portability of educational qualifications and on cross-border institutional cooperation.

Annex 4: Analytical methods

Costs per procedure

The administrative costs per applicant are estimated at approximately EUR 330 per procedure (median), comprising six components derived from question 17 of the citizens/professionals survey: fees paid to the qualification-issuing institution and the home competent authority, certified translation costs, notarisation and apostille fees, and postal or courier charges, together with the host CA application fee. The mean total is EUR 867, reflecting a right-skewed distribution driven primarily by translation costs and host CA fees. These figures should be interpreted as EU27 central estimates across heterogeneous procedures, professions and MS — not as uniform costs applicable to all cases — given that costs vary substantially between automatic recognition and general system procedures, across professions, and across MS with different fee structures. The breakdown of cost components is presented in the table below.

Source: citizens/professionals survey, Q17; contractor’s calculations.

Two cost components warrant specific methodological comment. For certified translation, the median of EUR 150 was adopted on the full numeric distribution, inclusive of two high-end observations (EUR 2 000 and EUR 4 000), which are plausible for complex multi-document dossiers requiring sworn translation; this figure is consistent with the EUR 100–400 per document range confirmed by Scholz and Rohr. 163 For the host CA application fee, the distribution is bimodal: approximately 81 out of 203 respondents reported zero fees, consistent with SWD(2026)64 and the GoC Workshop of 10 February 2026 (11 out of 28 reporting no fee formula); at the upper tail, fees extend to EUR 17 500 for licensed professions (ECA 2024-10 §44). The median of EUR 50 is adopted as the central estimate, with the mean of EUR 223 serving as an upper bound. This is broadly consistent with SWD(2026)64 (median EUR 200, mean EUR 411, n=284) and with the SPI consultation, where among EU citizens with direct recognition experience and valid cost responses (n=46), 20 reported total costs in the EUR 1–250 band and approximately 13 reported costs above EUR 500.

The variable cost borne by competent authorities is estimated at approximately EUR 950 per procedure and comprises two components: variable staff cost (EUR 623) and other variable operating costs (EUR 327). The staff component is derived from questions 9, 11 and 18 of the competent authority survey. Question 9 asks respondents for the average annual salary of staff involved in managing the recognition process. After cleaning, the median is EUR 32 000: eight responses below EUR 5 000 were converted from monthly to annual figures (×12), consistent with the geographic distribution of the respondents concerned, and one extreme outlier (EUR 902 743) was removed, leaving 58 valid responses; the mean of EUR 37 299 is retained as an upper bound. The median has been benchmarked against the Eurostat Structure of Earnings Survey 2022 (EU-27 mean annual gross earnings for ISCO-08 OC2 Professionals), which returns a comparable order of magnitude for mid-level administrative staff, and significant cross-country variation in the underlying responses is acknowledged. Over 220 working days, this implies a daily staff cost of approximately EUR 145. Questions 11 and 18 ask respondents to report, in man-days, the annual effort devoted to each activity in the recognition process. Question 11 covers the preliminary stage — maintenance of national portals and the Single Digital Gateway interface, responses to pre-application enquiries, consultation and updating of the Regulated Professions Database, issuance of outgoing certificates — and question 18 covers core case processing: digitisation of paper files, staff training on IMI, EPC and PQD requirements, verification of document authenticity, assessment of training equivalence, communication through IMI, drafting of decisions, and handling of appeals. Applying arithmetic midpoints to the ordinal response classes gives a total of 220.5 man-days per authority per year. The share of that workload which varies with the number of cases handled corresponds to approximately 4.3 man-days per procedure, which at EUR 145 per day gives a staff cost of approximately EUR 623 per procedure. The second component reflects the non-staff operating costs directly associated with the processing of individual recognition cases. It is based on question 17 of the competent authority survey, which collects annual monetary expenditure for case-related operating costs, including electronic templates, servers, IT services, telephony, cybersecurity and data protection compliance, printing and staff training. These costs are estimated to amount to approximately EUR 327 per procedure. The two components together give the variable cost of approximately EUR 950 per procedure.

Added to the EUR 330 borne by the applicant, the EUR 950 gives the total per-procedure burden of EUR 1 280 used throughout the analysis.

Administrative costs borne by employers

The relevant sub-population for the application of these costs is the share of recognition procedures with active employer involvement. Out of the 159 SME respondents to the SME Panel Survey, 19 respondents reported that recognition procedures are handled directly by the employer on behalf of the prospective employee, 47 reported that the employer supports the procedure while the employee retains responsibility for it, and 24 respondents reported that the procedure is handled independently by the employee. Based on this, we assume that around 12% of procedures are handled directly by the employer on behalf of the prospective employee, around 30% are supported by the employer with the employee retaining responsibility for the procedure, and around 15% are handled independently by the employee. 164  

The sub-population to which the per-hire cost is applied is derived directly from the SME Panel Survey, Table 8: applying the 12% share of employer-handled procedures to the SCM baseline of 53 000 procedures per year gives a sub-population of approximately 6 360 procedures per year. The 30% share of procedures supported by the employer but for which the applicant retains responsibility for the procedure and bears the out-of-pocket fees is documented qualitatively in this analysis but is not included in the quantitative calculation, as those fees are already accounted for under the applicant-side compliance costs (citizens/professionals survey Q17, average EUR 330 per procedure), and the corresponding employer support takes the form of HR time and managerial backing not separately quantified in an additive way in the SME Panel Survey evidence base.

These estimates are methodologically distinct from the cost components already captured above for the applicants, and double counting is excluded by construction through the sub-population restriction. The applicant-side compliance costs reported in question 17 of the citizens/professionals survey 165 — fees charged by the qualification-issuing institution, fees charged by the home competent authority for official documents, certified translation, notarisation, postal or courier costs and host competent authority fees, totalling on average EUR 330 per procedure — are out-of-pocket costs paid by the applicant directly when the applicant is responsible for the procedure. The competent-authority-side costs derived from the CA survey — variable staff time and other variable components, totalling on average EUR 950 per procedure — are borne by the receiving authority. The employer-borne costs documented by the SME Panel Survey — covering the full set of costs an employer reports incurring when handling the recognition procedure on behalf of the employee, including recognition body fees paid by the company in lieu of the applicant, internal HR administrative time and external consultancy or legal support — are sustained by the hiring organisation only in the 12% of procedures handled directly by the employer. The application of the employer-borne unit cost (EUR 814 per hire) to this restricted sub-population avoids double counting with the applicant-side estimate: in the remaining 88% of procedures, the applicant pays the out-of-pocket fees and these are accounted for under Q17 of the citizens/professionals survey. The difference in magnitude between the applicant-side fees captured by Q17 (around EUR 110 in cumulative fees across the qualification-issuing institution, home CA and host CA components) and the SME Panel Survey 'fees for recognition bodies' (mean EUR 407, n=14) reflects the broader cost perimeter captured by the employer-side question, which includes ancillary fees and costs incurred by the firm in the management of the recognition file beyond the strict application fees borne by the applicant.

The integration of employer-borne administrative costs into the structural cost-savings analysis strengthens the evidence base for the comparative assessment of the three policy options and reinforces the policy relevance of the initiative for cross-border labour-market matching. SME Panel Survey respondents identify reduced administrative burden during recruitment as the most widely anticipated benefit of a common EU digital recognition system (108 out of 159 respondents), followed by faster recruitment processes (97 out of 159) and easier hiring from other MS (80 out of 159). 166  Position papers from BusinessEurope and SMEUnited provide qualitative confirmation that recognition barriers weigh disproportionately on small and medium-sized enterprises, which lack the dedicated human-resources capacity available to larger firms. 167  While the order of magnitude of the quantified savings remains modest in aggregate terms, their strategic significance lies in the contribution to addressing persistent labour shortages in regulated professions, a structural concern documented across MS by recent EU-level labour market analyses.

Monetised time savings

The recognition procedure imposes a significant opportunity cost on applicants who are unable to practise during the period in which their qualifications are under assessment. Survey evidence from the citizens/professionals survey indicates that 23 out of 48 respondents reported being entirely unable to work during the recognition procedure - for the purposes of the analysis, this evidence is used to support the assumption that 47.9% of applicants are unable to work while their recognition procedure is ongoing, 168 while 7 out of 25 169 of those who were able to work reported being employed in roles not in line with their qualification level. For the time savings analysis, the relevant counterfactual is not the median observed procedural duration but the reduction in processing timelines expected from the measures under each policy option: under the package of measures envisaged, recognition decisions for the seven professions covered by automatic recognition under Title III, Chapter III of Directive 2005/36/EC would be expected to benefit from shorter processing timelines, with an indicative reduction from around three months to around one month for automatic recognition procedures and from around four months to around three months for procedures handled under the general system — corresponding to a gain of two months and one month respectively. 170

The time savings analysis is segmented accordingly between the two procedural groups. Drawing on RegProf data, the seven professions covered by automatic recognition on the basis of minimum training requirements account for around 46% of total establishment decisions across all regulated professions in the EU during the years 2020-2024 171 . Applied to the SCM baseline of 53 000 procedures per year, this implies approximately 24 380 procedures per year falling under automatic recognition based on minimum training requirements and approximately 28 620 falling under the other recognition regimes. The monthly monetised time savings is approximated using occupational wage proxies from the Eurostat Structure of Earnings Survey 2022, EU-27 aggregate, mean annual gross earnings, enterprises with 10 or more employees: in the order of EUR 50 000 for ISCO-08 occupational group OC2 (Professionals), used as the proxy for nurses and medical doctors in the automatic group, and an average between OC2 and OC7 Craft and related trades workers — in the order of EUR 40 000 172  — used as the proxy for engineers and electricians in the non-automatic group. 173 These figures correspond to monthly opportunity costs in the order of EUR 4 000–4 500 and EUR 3 000–3 500 respectively, consistent with OECD Health at a Glance 2023 estimates of the gross annual remuneration of hospital nurses across the largest EU MS 174 . The time savings associated with each policy option is then estimated by combining the volume of procedures in each group, the corresponding reduction in processing timelines (two months for the automatic group, one month for the general system), the monthly opportunity cost proxy, the share of applicants unable to work during the procedure (47.9%, Q21), and a realisation factor reflecting the expected degree of effective implementation under each policy option (60% under PO1, 75% under PO2, 95% under PO3), consistent with the calibration adopted elsewhere in this Section. On this basis, the estimated annual reduction in applicant-side forgone wages — that is, the monetised time savings accruing directly to recognition applicants in the form of earlier access to professional activity — is approximately EUR 80.7-91.8 (midpoint: 86.2) million per year under PO1, EUR 100.9-114.8 (midpoint 107.8) million per year under PO2, and EUR 127.7-145.4 (midpoint 136.6) million per year under PO3.

Sensitivity of the monetised time savings

The monetised time savings for applicants constitute the largest component of the quantified benefits: EUR 1 281.7 million of the EUR 1 550.9 million estimated for the preferred option in cumulative present value over 2029–2040. They are derived from a multiplicative model with five parameters: the number of procedures in each procedural group, the reduction in processing timelines expected under each policy option, the monthly wage proxy for each group, the share of applicants unable to work during the procedure, and a realisation factor. Since the model is multiplicative, a given percentage change in any one parameter produces the same percentage change in the result. The analysis below therefore sets out the plausible range of each parameter and the range of the aggregate that follows from it.

The share of applicants unable to work during the procedure (47.9%, Q21 of the citizens/professionals survey) is estimated on a sample of 48 respondents, with a 95% confidence interval of 33.8%–62.0%. Applying the bounds of the confidence interval isolates the effect of sampling uncertainty on the aggregate.

The wage proxies drawn from the Structure of Earnings Survey (EUR 50 000 for ISCO-08 OC2 Professionals in the automatic group; EUR 40 000 as the average of OC2 and OC7 for the general group) are varied by ±20%. The variation is a deliberately conservative assumption adopted solely to test the robustness of the result. It is not derived from an observed distribution: its purpose is to establish how far the estimate moves under a plausible departure from the central wage values, which is the function a sensitivity test is intended to perform.

The expected reduction in processing timelines (two months for automatic recognition, one month for the general system) is halved, to one month and half a month. This is the most demanding of the tests, since the timeline reduction depends on how the measures are implemented and no ex-post evidence is available.

The split between the two procedural groups (around 46% of establishment decisions under the automatic system, from RegProf data, giving approximately 24 380 procedures a year against 28 620 under the general system) is varied by ±10 percentage points, allowing for a change in the composition of the procedure population over the appraisal period.

The realisation factors (60%, 75% and 95% under PO1, PO2 and PO3) are reduced by 10 percentage points, as in the test already applied to the administrative cost savings.

Results – annual monetised time savings (EUR million)

Δ on PO3 is the variation relative to the central estimate for the preferred option.

Results – cumulative present value 2029–2040, discounted to 2026 at 3% (EUR million)

The assumed reduction in processing timelines drives most of the variation. Halving the expected time gains lowers total benefits by 41%, to EUR 910.1 million. This parameter depends on how effectively the measures are implemented and cannot be observed ex ante; it is the main source of uncertainty in the assessment.

Sampling uncertainty in the share of applicants unable to work is smaller. At the lower bound of the confidence interval, total benefits fall by 24.4%, to EUR 1 172.8 million. The estimate stays within the same order of magnitude, and PO3 remains the option with the highest benefits under every scenario tested. The size of the sample affects the precision of the figure, not the ranking of the options.

Applying the lower bound of the confidence interval, wage proxies 20% lower, halved timeline gains and realisation factors reduced by 10 percentage points at the same time gives total benefits of EUR 592.7 million against estimated costs of EUR 59.0 million for the preferred option. The combined pessimistic scenario is intentionally extreme, as it simultaneously applies conservative values to several independent parameters. It should therefore be interpreted as a lower-bound stress test rather than as a plausible central scenario. The conclusion that benefits exceed costs by a wide margin does not rest on any single assumption.

The figures are reported as indicative orders of magnitude rather than as point forecasts, and the ranges above give the interval within which the aggregate can reasonably be expected to fall.

Qualitative and non-quantifiable dimensions

Several dimensions of material significance cannot be quantified but are substantiated by primary and secondary evidence. The deterrence effect — likely reflecting professionals who do not initiate procedures due to perceived complexity — is documented in the SPI public consultation (n=785, 37% rating recognition processes as a very big problem), and consistent with Adamis-Császár et al., 175 who find that administrative burden in professional recognition is associated with statistically significant reductions in intra-EU labour mobility. Eurostat EU-LFS (lfsa_egai2d) overqualification rates among EU mobile workers remain persistently above those of comparable domestic workers, suggesting that recognition barriers compound skill mismatch beyond the formally registered procedure population.

The GoC Focus Group (4 March 2026) and the EU Representatives Focus Group (23 February 2026) provide qualitative confirmation that procedural complexity, documentation requirements and lack of predictability are among the dominant factors discouraging professionals from initiating or completing recognition procedures.

Per-procedure cost reductions: mechanism and calibration

The savings achievable under each policy option are estimated as percentage reductions in the baseline per-procedure burden of EUR 1 280, applied to the SCM baseline population of 53 000 procedures per year and discounted by a realisation factor reflecting expected implementation effectiveness. The gross savings ranges are calibrated on the basis of:

·Specific administrative bottlenecks documented in ECA Special Report 2024-10 — including document proliferation, deadline non-compliance, and fee opacity — and the extent to which each policy option directly addresses them;

·GoC Workshop (10 February 2026) on CA-side simplification drivers;

·Focus Group with professional associations (23 February 2026) on applicant-side friction points; and

·translation cost reduction potential from Scholz and Rohr. 176

The savings ranges are triangulated across survey evidence, stakeholder consultations, and documented administrative bottlenecks, and should be interpreted as informed and calibrated estimates grounded in the full body of primary and secondary evidence assembled for this study.

Realisation factors reflect the expected effectiveness of the policy option, i.e. the the extent to which the intended specific objectives are achieved in practice. They are calibrated based on qualitative evidence, institutional design, and comparable impact assessments.

Under PO1, a realisation factor of 60% is applied (40% discount), informed in part by Q29 of the CA survey, which provides indicative evidence of implementation uncertainty: 42% of respondents answered 'not sure / it depends' on whether simplification benefits would materialise. Under PO2, a realisation factor of 75% is applied (25% discount), reflecting the binding but transposition-discretionary character of the measures, consistent with EU impact assessment precedents for partial harmonisation directives. Under PO3, a realisation factor of 95% is applied (5% discount), reflecting the mandatory character of the provisions, with limited scope for national discretion following transposition, and a residual 5% for transitional implementation effects. These rates are informed structural assumptions, not empirically observed; they are subjected to sensitivity testing in the relevant section of this report. Central estimates throughout this section are derived as midpoints of the reported net saving ranges — that is, (minimum + maximum) / 2 — and used consistently for aggregation across all three policy options.

IT implementation costs across policy options

IT implementation costs have been estimated in line with standard project cots management methodologies, combining multiple techniques to ensure robustness and reliability. Estimates draw on established practices, expert validation, and analogous evidence from comparable EU digitalisation projects. Techniques applied include:

To arrive at the cost estimates, a number of assumptions have been made. Key assumptions were:

-Functionality that is currently in planning to improve the use of IMI for workflows would be available for the implementation of the EDRS, and would be used for its implementation (evidence: DG GROW confirmation of planned enhancements).

-Existing corporate solutions are re-used where possible, e.g. EU login, chatbot implementations (in line with Commission reuse policy).

-Under policy option 2, MS can opt to implement their national solutions or to use the EU-level system. Thus, between 0 and 27 MS would bear national implementation costs. For a realistic scenario it is assumed 11 MS with comprehensive, digitally mature recognition systems would develop independent solutions; while others would adopt the EU-level solution. 177

-Under policy option 2 it is assumed that (i) MS organise implementation in a cost-effective way, i.e. without unnecessary duplication of systems between competent authorities, (ii) a central national verification entity to verify the EUDI attestations can be made available, to be called by the single competent authorities to verify the received EUDI attestations, (iii) one single central issuer of recognition decision will issue attestations on behalf of the different competent authorities, and (iv) all competent authorities will connect to OOTS through national proxies.

Annex 5: Competitiveness check

1. Overview of impacts on competitiveness

The table below summarises the expected impacts of the preferred policy option (PO3) across the main dimensions of EU competitiveness. Impacts are rated on a scale ranging from ++ (significant positive impact) to -- (significant negative impact), with 0 indicating no material change compared to the baseline. References to the relevant sections supporting the assessment are provided.

2. Synthetic assessment

The synthetic assessment below summarises the overall competitiveness impact of the preferred policy option and its comparison with the alternative options.Among the three policy options assessed, PO3 generates the most significant positive contribution to EU competitiveness. This assessment is consistent with the multi-criteria assessment in this report.

On cost and price competitiveness, PO3 produces the largest absolute reduction in per-procedure administrative costs — central net saving of EUR 512.5 per procedure and EUR 27.2 million per year — substantially exceeding PO1 (EUR 81.5/procedure; EUR 4.3 million/year) and PO2 (EUR 243/procedure; EUR 12.9 million/year). The 95% realisation factor applied to PO3 reflects the mandatory and comprehensive character of its provisions, which distinguishes it structurally from the non-binding approach of PO1 and the partially binding approach of PO2. For businesses in regulated sectors relying on cross-border recruitment, this translates directly into lower labour input costs and more efficient access to qualified professionals. The net total system burden reduction under PO3 — approximately 26–39% of the EUR 67.8 million annual baseline — is positioned above the 25% indicative simplification reference point, while the corresponding reductions under PO1 (~1–3%) and PO2 (~10–14%) deliver progressively smaller improvements relative to the baseline.

On SME competitiveness, PO3 addresses the asymmetric burden that current recognition procedures place on smaller firms. The mandatory digital-by-default infrastructure eliminates precisely those administrative steps — paper documentation, manual verification, opaque fee structures — that are most costly relative to firm size. The SME Panel Survey (2026) confirms that SMEs anticipate average savings of 26–36% per cost category from a common EU digital recognition system, with the largest savings on internal administrative time (36%) and recruitment-related costs (34%).

On international competitiveness and capacity to innovate, PO3's effects are indirect but consistent in direction. Improved intra-EU professional mobility supports the EU's ability to address structural skills shortages in globally competitive sectors, reduces brain waste, and strengthens the digital infrastructure of public administrations. PO1 and PO2 generate positive competitiveness effects relative to the baseline, but of materially lower magnitude. PO2 reaches approximately 15–22% per-procedure savings and a 10–14% total burden reduction — a material improvement, but insufficient to reach the simplification threshold or to address the structural digitisation deficit that is most damaging to EU competitiveness.

3. Competitive position of the most affected sectors

The table below presents the current competitive position and the expected impact of PO3 for the five sectors most significantly affected by recognition barriers—healthcare and social services, construction and craft trades, manufacturing and engineering, education, and professional and scientific services. This selection is based on evidence consulted in the study supporting this impact assessment (BusinessEurope (2024), SMEUnited (2024), the SME Panel Survey (2026), the European Labour Authority (2024) and ECA Special Report 2024-10).

Annex 6: SME check

Overview of impacts on SMEs

Annex 7: The PQD and the rest of the Single Market acquis

The PQD applies to EU citizens who have obtained their professional qualifications in one MS (the home MS) and wish to practise a regulated profession in another MS (the host MS). It plays a crucial role in supporting the effective functioning of the Single Market by giving practical effect to the fundamental freedoms of movement of workers, establishment, and the provision of services (Articles 45, 49, and 56 of the Treaty on the Functioning of the European Union - TFEU).

Broadly speaking, the Directive provides for three main recognition systems: 

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

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

Under automatic recognition based on minimum training requirements, which applies to seven professions—mainly in the health sector—professionals apply to the host MS, but authorities do not verify the content or duration of training. Qualifications listed in Annex V of the PQD are deemed to meet minimum training standards and are automatically recognised across the EU.

In addition, professionals who are legally established in one MS and wish to provide services on a temporary and occasional basis in another MS may generally do so without undergoing a formal recognition procedure, although a prior declaration may be required in certain cases

As an instrument enabling qualified professionals to establish themselves or to provide services on a temporary and occasional basis in another MS, the PQD is closely linked to, and operates in complementarity with, the Services Directive (2006/123/EC), which lays down general provisions facilitating the free movement of services across MS. However, as regards regulated professions, pursuant to Article 3(1)(d) of the Services Directive, where its provisions conflict with those of the PQD, the PQD prevails.

This is expected to remain unaffected by the possible adoption of future sector-specific instruments in the field of services, such as the envisaged Construction Services Act or comparable initiatives targeting particular economic sectors. While such instruments may introduce additional or more tailored rules governing the provision of services, they would not displace the PQD in matters relating to access to and the exercise of regulated professions. In this respect, the PQD retains its role as the central legal framework governing the recognition of professional qualifications.

At the same time, the PQD does not constitute the sole legal instrument governing regulated professions at Union level. It establishes a horizontal system for the recognition of professional qualifications applicable across a wide range of professions, which is sometimes complemented by sector-specific instruments reflecting the particular characteristics and regulatory needs of certain professions. For example, in the case of lawyers, Directive 98/5/EC facilitates the permanent establishment of lawyers in another MS under their home-country professional title, while Directive 77/249/EEC governs the provision of legal services on a temporary basis.

Finally, it is important to distinguish clearly between professional recognition, which falls within the scope of the PQD, and academic recognition. The PQD governs the recognition of professional qualifications for the purpose of granting access to and enabling the pursuit of a regulated profession in a host MS. By contrast, academic recognition concerns the recognition of diplomas and periods of study for the purpose of accessing further education or training. In this context, initiatives under the European Research Area, including the forthcoming European Research Area Act, aim to facilitate the mobility of researchers and the circulation of knowledge and skills, with a focus on academic and research pathways. These instruments pursue objectives distinct from, yet complementary to, those of the PQD, which will continue to provide the legal framework governing access to regulated professions and supporting the cross-border mobility of professionals within the Union.

Annex 8: The landscape of regulated professions in the EU

Which professions are regulated?

A profession is considered as ‘regulated’, if law requires people to have a specific qualification to access and/or pursue the profession.

There are two types of regulated professions ( 182 ):

a)7 key professions that are regulated in all MS, and where Directive 2005/36/EC requires MS to apply harmonised minimum training requirements: doctors, nurses, midwives, dentists, pharmacists, veterinarians and architects. These are regulated in all MS.

b)More than 5.000 professions that MS decided to regulate on national level, usually for reasons of public health, safety or protection of the service recipient. These are often regulated in a subset of MS. MS must respect the limits of proportionality when regulating professions. (cf. Proportionality Test Directive)

Examples of professions with different degree of regulation

Nurses – A profession with harmonised minimum training requirements. Regulated in all MS. Falls under the “automatic recognition system”, i.e. the qualification gives the right to obtain recognition in other MS (no “case-by-case” assessment).

Engineers – Some degree of regulation, but not all types of engineers are regulated, and not in all MS. E.g. civil engineers are regulated in 15 MS, electrical engineers in 6 MS and industrial engineers in 4 MS.

Plumbers – Like many other professions in crafts and construction, plumbers are regulated in a subset of MS (in this case 9).

Cooks – An example for a profession that is unregulated in most MS, but 2 MS do regulate.

AI engineers – A relatively new profession. Like almost all professions in ICT this is unregulated in all MS. However, if a higher impact on health and safety is observed, this might change, and countries might want to regulate it in future.

The RegProf database provides an overview of regulated professions in the MS.

Regulation as a barrier in the Single Market

While it can be justified in view of overriding reasons of public interest, regulation of professions creates barriers to entry. Moreover, when regulations diverge between MS, this makes it more difficult for people to move between professions.

EU nationals that want to work in a regulated profession in another MS than the one where they obtained their qualification need to demonstrate that they are qualified for that profession, i.e. they need to obtain recognition from the CA in the host MS. Thus, recognition is necessary whenever an EU national moves to the MS (to establish there) where a profession is regulated, no matter if it is regulated in their home country, or not.

Directive 2005/36/EC regulates the procedures to be applied by the MS for the recognition of professional qualifications. There are different regimes applicable to different sets of professions (e.g. automatic recognition based on minimum training requirements, automatic recognition based on professional experience, general system of recognition, common training test, common training framework).

Service providers that temporarily and occasionally want to provide services in another MS in a profession regulated in that country, can be required to submit a prior declaration (but not – to request recognition). Only in exceptional cases they may be subject to prior checks.

Overview of regulated professions in the EU

¾Regulated professions can be found across all sectors (e.g. healthcare, education, construction, manufacturing, business services, tourism, …).

¾Regulated professions are not equal in size, i.e. they cannot be directly compared. There are for example 3.7 million nurses working in the EU, 2 million doctors and 611.000 physiotherapists. On the other hand, some regulated professions are niches in the labour market and cover only few thousand professionals (e.g. orthoptists, airport firefighters or mining supervisors)

¾There is a very high degree of overlap between regulated professions and shortage professions. Most of the shortage professions are regulated in some MS, and most of the regulated professions are in high demand.

Overview by groups of sectors

Divergences between Member States

With the exception of the seven professions for which the PQD establishes minimum training requirements, regulation of professions falls entirely within the competence of the MS. The latter decide which professions are regulated, what qualifications are required, and which authorities oversee access to and the exercise of the professions in question.

As illustrated in the graph below, the number of regulated professions differs significantly across MS. 184

Number of regulated professions under the general system per Member State based on information in the Regulated Professions Database.

As emphasised in the Staff Working Document accompanying the Report from the Commission on the implementation of Directive 2005/36/EC on the recognition of professional qualifications, these numbers should be appropriately contextualised and interpreted with caution as some Member States may regulate a bundle of professional activities as one profession, while other may regulate each of these activities separately. Moreover, a Member State might regulate fewer professions but impose stringent requirements and detailed conditions on each, whereas another might regulate a larger number but with less stringent criteria. Understanding the specific regulatory environment of any given Member State, therefore, involves examining not only the number of professions regulated but also the depth, restrictiveness, and underlying factors driving these regulations.

While on average approximately 22% of those employed in the EU work in a regulated profession, 185 the share of professionals employed in regulated professions varies considerably across MS as emphasised by the graph below:

+

Share of regulated professions in total labour force, 2015 186

Data from the RegProf for 2020–2024 also shows that MS are not equally involved in the recognition of professional qualifications. While for example Romania (15.8%), Spain (12.0%), Belgium (9.2%), Germany (8.2%) and France (7.6%) account for the largest shares of professionals seeking recognition in another MS, Cyprus, Estonia, Luxembourg and Ireland account for only between 0.04% and 0.4% of professionals seeking recognition in another MS.

Conversely, Germany (17.6%), Italy (14.7%), France (12.2%), Belgium (11.5%) and Luxembourg (7.8%) receive the largest shares of applications, while for example Bulgaria, Estonia, Luxembourg and Ireland only receive between 0.04% and 0.2%.

Annex 9: Expansion of automatic recognition through CTFs

The expansion of automatic recognition is covered by the present impact assessment in the baseline. This is because such expansion would be implemented through delegated acts adopted on the basis of an existing empowerment under Article 49a of the PQD. As such, it does not require the establishment of a new legal basis, but rather builds on, and improves where necessary, the current framework. Moreover, the extension of automatic recognition does not, in itself, address the core problems identified in this impact assessment. While automatic recognition facilitates access to certain professions, it remains subject to procedural and administrative constraints which can affect its efficiency in practice. The assessment of the policy options therefore focuses on measures aimed at improving the functioning, speed and transparency of recognition procedures overall. Any future extension of automatic recognition would benefit from these horizontal improvements, rather than constituting a standalone solution to the problems analysed here. However, the review of the PQD will provide an opportunity to introduce a multi-year planning instrument (in the form of a periodically updated working plan) under the Directive to better streamline the process and organise preparatory work on those delegated acts.

As announced in the 2026 Implementation Report, efforts are underway to establish a CTF for physiotherapists. The draft delegated act establishing a Common Training Framework for physiotherapists was published at the end of May 2026 for a four-week public feedback period. 187 This followed the publication, in March 2026, of a report prepared by the Commission and its contractor, which analysed and substantiated the commonalities in the regulation and training for the profession of physiotherapist across Member States. 188

In addition, the Commission is working to identify additional professions for which CTFs could be developed in the future and reflections are on-going on how to further streamline and structure the process for the selection, prioritisation and assessment of suitable professions for a CTF in the medium-term, in close cooperation with the MS, the professional organisations concerned and other stakeholders. More concretely, the Commission has been working with its contractor to identify an initial list of around ten professions that could be suitable for the development of CTFs, in line with the requirements of Article 49a of the PQD.

This would be supported by the measure envisaged in this impact assessment which seeks to establish a more structured and systematic approach to expanding automatic recognition through a work programme with annual outputs and a multiannual planning perspective agreed with the Group of Coordinators to steer the development of CTFs. This would help make fuller and more effective use of the possibilities for automatic recognition already provided for in the PQD.

Annex 10: User journey of applicants to regulated professions

Annex 11: Measures considered 

PO1:Convergence of administrative practices through shared standards

PO2: Targeted procedural reforms for improved interoperability

Policy option 3: Unified EU workflow and enhanced enforcement 

Measures that could support all policy options

Launch a pilot on chatbots as tools to support information provision to applicants

The Commission develops and launches EU‑supported pilot to deploy chatbots that guide applicants through recognition requirements and documentation steps. The chatbot provides standardised answers and directs users to the correct EU and national sources. The pilot generates a common model that MS may adopt or adapt in the future. Pilots would be implemented with a limited number of volunteering MS and professions, with national authorities responsible for validating content and accuracy. Monitoring would entail the development of indicators (e.g.: usage rates, types of queries handled, user satisfaction and reduction in incomplete or incorrect applications. Participation is entirely voluntary; no enforcement applies. Pilots would be launched in the short term (1-2 years). Results would inform possible scaling-up in the medium to long-term.

Amend the Directive to include a provision on cooperation between the Commission and the MS, providing for the adoption of an annual work programme by the expert group on recognition of professional qualifications and its subgroups.

On this measure, see also Annex 9. Cooperation among CAs, and between CAs and the Commission, would benefit from strengthened governance within the Group of Coordinators and its subgroups. The introduction of annual work programmes within a multiannual perspective would help ensure that the expert group supports the Commission not only in the consistent implementation of the PQD, but also in making fuller and more systematic use of the opportunities already provided for in the Directive. This concerns, in particular, the delegated powers available under the PQD. A concrete example is the development of CTFs, which can extend automatic recognition to professions currently covered exclusively by the general system. Enhanced cooperation within the expert group would support a more structured and predictable approach to identifying priority professions and facilitating the development of CTFs, one of the work strands under Action 2 of the SPI.

Annex 12: Discarded measures

The table below presents the policy measures that were considered but ultimately discarded, organised by the problem drivers they were intended to address. These measures were screened against a set of knockout criteria to determine whether they should be retained or excluded at this stage.

The following criteria were applied:

·Legal feasibility: the extent to which a measure is compatible with the EU Treaties, consistent with existing EU legislation (including Directive 2005/36/EC), and can be implemented without requiring disproportionate legal amendments.

·Political feasibility: the likelihood that the measure can secure sufficient support from EU institutions, MS and relevant stakeholders to be realistically adopted.

·Effectiveness: the extent to which the measure is capable of achieving the intended policy objectives.

·Efficiency: the extent to which the expected benefits are proportionate to the associated costs.

·Relevance: the degree to which the measure directly addresses the identified problem drivers and contributes to the specific objectives.

·Coherence: the extent to which the measure is consistent with other EU policies, initiatives and internal market principles, avoiding overlaps or contradictions.

·Proportionality: the extent to which the measure does not go beyond what is necessary to achieve the objectives and remains proportionate to the scale of the problem.

·Identifiability: the clarity and precision of the measure, including whether its scope, obligations, target groups and expected effects can be clearly defined and operationalised.

·Subsidiarity: the extent to which EU action is justified, in that the objectives cannot be sufficiently achieved by MS acting alone and can be better achieved at EU level.

1. Fragmented and inconsistent information available to applicants

2. Process inefficiencies

3. Fragmented administrative cooperation

Annex 13: Direct cost impacts

The first three tables below present the estimated savings generated under Policy Options 1, 2 and 3. A methodological note is provided below the table for Policy Option 1 to explain the calculation approach and the derivation of the final results. The same methodology, assumptions and calculation approach apply equally to the estimates presented for Policy Options 2 and 3.

PO1: Administrative cost-savings per procedure for applicants and CAs (EUR)

Source: citizens/professionals survey (Q17), CA survey (Q9, Q11, Q18); Scholz and Rohr; authors' calculations. Gross saving percentages are derived from survey responses on anticipated cost reductions, focus group consultations and bottlenecks documented in ECA Special Report 2024-10; gross EUR values are computed as the gross percentage applied to the baseline cost component. Net savings apply the 60% realisation factor — an analytical calibration parameter reflecting the expected uptake of non-binding measures, by analogy with comparable evidence on voluntary EU coordination instruments (ECA Special Report 2024-10; SMET 2020) — to the minimum and maximum gross savings. The central estimate (EUR 81.5 per procedure) is the midpoint of the resulting net range (EUR 55–108).

Note (of relevance also to calculations for PO2 and 3 below):

The estimated savings are derived from a baseline administrative cost of EUR 1 280 per recognition procedure, consisting of EUR 330 borne by applicants (citizens/professionals survey, Q17) and EUR 950 borne by competent authorities (CA survey, Q9, Q11 and Q18), applied to an annual volume of more than 53 000 procedures. Savings are expressed as a net percentage reduction of this baseline, corresponding to approximately 4–8% under Policy Option 1, 15–22% under Policy Option 2 and 33–47% under Policy Option 3. These percentage reductions were calibrated and triangulated on the basis of multiple sources of evidence, including the cost-reduction responses collected through the applicant and competent authority surveys, consultation polls conducted during the GoC Workshop (10 February 2026) and the EU Representatives and ENIC-NARIC/PES/CSO Focus Groups (23–26 February 2026) where reductions were placed in bands (up to 10%, 10–25%, or more than 25%), evidence on procedural bottlenecks identified in ECA Special Report 2024/10, and the translation-cost evidence reported by Scholz and Rohr. As regards the realisation factor, the 60/75/95% figure is not a single multiplier applied to the component sum. Rather, it is a calibrated factor that condenses a multi-stage correction of the gross benefits: a business-as-usual adjustment, an attribution adjustment, and a likelihood adjustment. This is consistent with the Better Regulation Toolbox CBA approach.

The savings presented in these tables are calibrated at the aggregate level and therefore do not correspond to the simple sum of savings estimated separately for each individual cost component. A component-by-component calculation would provide a more conservative, bottom-up estimate and is useful for illustrating the specific sources of savings. However, it would not fully capture benefits that are more difficult to attribute to individual cost lines, such as shorter processing times, fewer incomplete applications, reduced requests for supplementary information, and fewer delays in cross-border cooperation. The methodology used for the tables was therefore designed to estimate the overall reduction in administrative burden per procedure on the basis of the full body of available evidence and then apply this calibrated reduction to the baseline cost per procedure. This approach also ensures consistency across the quantification of administrative savings, monetised time savings and employer-borne savings, all of which are based on calibrated net ranges and their midpoints. Finally, it provides a more robust estimate by relying on the convergence of multiple sources of evidence rather than on minimum and maximum estimates for each individual cost component.

PO2- Administrative cost-savings per procedure (applicants and CAs) (EUR)

Source: citizens/professionals survey (Q17), CA survey (Q9, Q11, Q18); GoC Workshop (10 February 2026); Scholz and Rohr (2026), in the study supporting this impact assessment. Calculation methodology follows the approach set out in the PO1 sub-section. The 75% realisation factor reflects the binding character of the measures (procedural deadlines, document caps, fee transparency obligations) subject to MS transposition discretion, calibrated by analogy with the implementation of comparable binding EU instruments (eIDAS Regulation; Single Digital Gateway Regulation 2018/1724). The central estimate (EUR 243 per procedure) is the midpoint of the resulting net range (EUR 198–288).

PO3: Administrative cost-savings per procedure (applicants and CAs)

Source: citizens/professionals survey (Q17), CA survey (Q9, Q11, Q18); GoC Focus Group (4 March 2026); Scholz and Rohr (2026), in the study supporting this impact assessment. Computation of savings is consistent with the methodology described in the PO1 sub-section. The 95% realisation factor — set higher than in PO1 (60%) and PO2 (75%) — reflects the mandatory character of PO3 provisions and the very limited margin for national discretion following transposition, calibrated by analogy with the implementation profile of binding EU instruments backed by enforcement mechanisms. The central estimate (EUR 512.5 per procedure) is the midpoint of the resulting net range (EUR 417-608).

Comparative summary

The table below brings together the per-procedure and aggregate annual cost estimates (per-procedure cost × 53,000 baseline procedures) across the three policy options and the baseline, providing a synthetic basis for comparison.

Comparative summary of costs and cost-savings (applicants and CAs) by policy option