Main provisions of Directive 2005/36/EC

The Recognition of Professional Qualifications Directive (PQD) was adopted in September 2005 and fully transposed by Member States by September 2010, almost three years after the transposition deadline of 20 October 2007 set out in its Article 63.

The directive seeks to support two core freedoms of the internal market: the free movement of persons and services, as established in Article 26 of the TFEU. As outlined in the recitals, 'for nationals of the Member States, this includes, in particular, the right to pursue a profession, in a self-employed or employed capacity, in a Member State other than the one in which they have obtained their professional qualifications' (recital 1). It is also recalled that Article 53 of the TFEU provides for the adoption of directives to ensure the mutual recognition of diplomas, certificates and other formal qualifications.

Article 1 sets out the purpose of the PQD, establishing a framework under which a Member State that requires specific qualifications for a regulated profession must recognise those obtained in other Member States. A definition of 'regulated profession' is provided in Article 3(1), referring to a 'professional activity or group of professional activities, access to which, the pursuit of which, or one of the modes of pursuit of which is subject, directly or indirectly, by virtue of legislative, regulatory or administrative provisions to the possession of specific professional qualifications'. The scope of the directive applies only to nationals of Member States, both employed and self‑employed (Article 2).

Service provision on a temporary and occasional basis in another Member State, while remaining established in the home country, does not require prior recognition of qualifications. Instead, a yearly prior declaration must be submitted to the host Member State (Article 7). This applies to individuals who have pursued the profession for at least one year in an EU Member State within the previous 10 years (Article 5), except for professions with public health and safety implications. In contrast, establishment on a permanent or stable basis in another Member State requires formal recognition of qualifications through the three types of procedures set out under the PQD.

The first type of procedure is the 'general system' (Article 10), under which recognition is granted on a case-by-case basis. It applies to professions not covered by the other two recognition schemes (see below). Citizens must submit an application and provide documentation, including proof of nationality, evidence of their qualifications and, where relevant, proof of professional experience. A competent authority in the host Member State is responsible for assessing whether the applicant's qualifications correspond to those required for access to the profession at national level.

For applicants from a Member State where the profession is not a regulated one and who are seeking to establish themselves in a country where it is, the PQD requires them to either demonstrate at least two years of professional experience over the previous 10 years or prove completion of regulated education or training (Article 13).

If significant differences between qualifications are identified and cannot be compensated for by professional experience or lifelong learning, the host Member State may impose compensatory measures, such as an aptitude test or an adaptation period (Article 14). Once completed successfully, the applicant is granted recognition and may legally exercise the profession in the host Member State.

A second system is recognition based on professional experience (Article 16), primarily applicable to professions in the crafts, trade and industrial sector for which no harmonised minimum training requirements exist at EU level. Under this approach, professionals who can demonstrate sufficient and certified experience in a regulated profession in one Member State may obtain recognition in another without undergoing a detailed comparison of qualifications. Applicants must provide official evidence confirming that they have lawfully and effectively exercised the profession for a specific period, typically ranging from two to six years depending on the activity and level of training (as laid out in Articles 17‑19). This system applies in particular to the activities listed in Annex IV of the Directive.

The third system establishes automatic recognition based on harmonised minimum training requirements at EU level (Article 21). It applies to a group of so-called 'sectoral' professions, for which the directive establishes minimum training conditions that must be met to qualify for automatic recognition. These include medical doctors (Articles 24‑30), nurses responsible for general care (Articles 31‑33), dentists (Articles 34‑37), veterinary surgeons (Articles 38‑39), midwives (Articles 40‑43), pharmacists (Articles 44‑45) and architects (Articles 46‑49). While these minimum standards are harmonised at EU level, Member States may still establish higher requirements within their national education and training systems.

Automatic recognition may also be granted to other professions through 'common training frameworks' (CTFs), agreed by at least one third of Member States at EU level. In such cases, recognition is based on a 'common set of minimum knowledge, skills and competences necessary for the pursuit of a specific profession' (Article 49a), jointly defined by participating Member States.

It is worth noting that professionals in five regulated professions (nurses responsible for general care, pharmacists, physiotherapists, mountain guides and real estate agents) may apply for recognition through a standardised online procedure, known as the European professional card (EPC) ⁶ (Article 4a). Managed by the European Commission through the internal market information system (IMI), this mechanism is designed to accelerate the recognition processes provided for by the directive.

Finally, the directive also addresses monitoring and flexibility measures. Article 60(2) requires the Commission to report on the transposition of the directive by January 2019 and every five years thereafter. Meanwhile, Article 61 allows for temporary derogations, enabling a Member State experiencing significant difficulties in a specific area to depart from certain provisions for a limited period, subject to the Commission's approval.

Commission implementation reports on Directive 2005/36/EC

In accordance with Article 60(2), the European Commission has produced three implementation reports of Directive 2005/36/EC since the transposition deadline of October 2007. These were published in 2011, 2020 and February 2026.

It should be noted that the timing of the reports did not always comply with the deadlines set out in Article 60(2). While the first implementation report was presented ahead of schedule (in 2011 instead of 2012), the 2020 report was issued after the deadline of January 2019. According to the Commission, the timing (and scope) of the reports evolved in line with changes to the directive's legislative framework.

In particular, the 2011 implementation report informed the subsequent revision adopted in 2013, which started to apply in 2016 and addressed several shortcomings identified in that assessment. The 2020 report, on the other hand, was specifically intended to examine the period between 2014 and 2019 and the changes introduced by the 2013 revision, including the EPC, the modernisation of the knowledge, skills and competences for the sectoral professions, and the introduction of CTFs. For this reason, no reports were issued between 2011 and 2020, despite the five-year reporting requirement.⁷

The latest implementation report, published on 20 February 2026, covers the period 2020‑2024 and examines the functioning of the directive in the policy context at the time.⁸ Despite the disruptions caused by the COVID‑19 pandemic, it confirms that the PQD has continued to support professional mobility across the EU, 'both for establishment and for the temporary provision of services'. ⁹ Over this period, Member States adopted around 185 000 decisions recognising professional qualifications for establishment, more than 83 % of which were positive. Additionally, around 40 000 professionals submitted declarations for the temporary provision of services.

The implementation report highlights clear differences in the performance of the three recognition systems. Automatic recognition based on minimum harmonised requirements is identified as the most efficient and user-friendly system. It typically involves limited documentation, lower costs and greater compliance with procedural deadlines, as competent authorities mainly verify the authenticity of the qualifications. Moreover, it plays a central role in supporting mobility in professions experiencing severe labour shortages, including doctors, nurses, pharmacists, dentists and certain technical occupations.

Recognition based on professional experience also offers, in principle, a simpler and faster route, but its use remains uneven across the EU. Procedures typically take between less than one and up to three months once the application is complete, and involve relatively few supporting documents. However, most decisions are concentrated in a small number of Member States¹⁰ accounting for over 70 % of cases during the reference period. According to the report, the reasons behind this uneven uptake remain unclear and warrant further analysis, particularly given the limited number of survey responses.

By contrast, the general system is considered more complex and administratively demanding. Applicants are often required to submit a substantial number of documents, which may vary across Member States. Although digital submission is becoming more widespread in the EU, procedures are not yet fully digitalised everywhere and may still involve paper-based documentation. The complexity of the process depends largely on how closely national regulatory frameworks align. Where differences are significant, applicants face greater difficulties in demonstrating equivalence and may be required to complete compensatory measures.

The implementation report also examines the role of common training frameworks, whose potential to expand automatic recognition remains largely untapped. Although they have attracted interest from professional organisations, no such framework has been established to date. This is mainly due to the difficulty of meeting the directive's requirements, including the need for sufficient participation by Member States and alignment of training systems.

Beyond the specific features of each procedure, several cross-cutting challenges affecting overall efficiency and accessibility are also identified. Information available to applicants is not always reliable or consistent, and awareness of existing support tools remains limited, particularly in the case of the European professional card, which is still underused. Its functioning is further constrained by technical and interoperability issues linked to uneven levels of digitalisation across Member States. More broadly, inefficiencies in administrative cooperation and document verification continue to hinder the performance of the recognition system, as procedures vary depending on national capacity and available resources.

At the same time, the report highlights the overall flexibility of the directive, through the possibility of updating minimum training requirements via delegated acts. This has allowed the legislative framework to keep pace with scientific and technical developments. Updates have so far been adopted for general care nurses, dental practitioners, pharmacists and veterinary surgeons. Stakeholder views remain divided, however, on how far these delegated powers should be extended.

Call for evidence and public consultations

On 5 December 2025, the Commission launched a call for evidence (CfE) for an impact assessment on the SPI. According to the CfE, two overarching objectives will be pursued by this initiative, namely strengthening the cross-border portability of skills within the EU and enhancing the Union's attractiveness for global talent. Both policy aims respond to persistent barriers that continue to hinder the recognition and transfer of qualifications and skills, which remain a structural obstacle to labour mobility.

The CfE notes, for instance, that employers do not always feel confident about assessing or interpreting qualifications obtained in other Member States. At the same time, EU tools designed to improve the transparency of qualifications are unevenly implemented. This is particularly the case for the European qualifications framework (EQF), as some Member States have not developed registries for their national qualifications frameworks (NQFs) or shared relevant data on the Europass platform , thus limiting the exchange of information.

Recognition procedures under the PQD can be lengthy and costly, as outlined in the previous section. In addition, for third-country nationals, recognition still relies on divergent national systems in the absence of a common EU framework. Although the non-binding 2023 Commission recommendation aimed to promote some convergence between Member States in this area, procedures remain fragmented and burdensome for third-country professionals. Current systems do not adequately capture skills acquired through work experience or non‑formal learning either, making it difficult to showcase them in the labour market. Limited use of digital tools in some Member States and the lack of interoperability between national systems further hinder the exchange and verification of information across borders.

To address these issues, the CfE outlines a range of potential policy options. While the types of specific measures are still to be defined, the initiative is expected to focus on three main areas of intervention.

A first possible legislative measure is expected to improve the transparency and comparability of qualifications and skills across Member States. According to a non-exhaustive list of possible measures included in the CfE, this could involve strengthening implementation of NQFs, ensuring that they are fully developed in all Member States and properly linked to the EQF, and regularly updated. Access to information could also be improved by making data on national qualifications more consistently available at EU level through platforms accessible to professionals, employers and public authorities. In addition, greater visibility of skills documented through micro-credentials could be promoted by integrating them into NQFs and ensuring it is possible to obtain micro-credentials through recognition of prior and non-formal learning.¹¹

Another line of intervention will address the modernisation and expansion of recognition processes for regulated professions under Directive 2005/36/EC. In this regard, the CfE points in particular to a possible extension of the automatic recognition system to encompass additional professions via delegated acts. The development of digital tools to streamline and modernise recognition procedures is also envisaged, suggesting a possible revision of the PQD.

A third strand is likely to concern the recognition of qualifications and skills of third-country nationals. Policy options under consideration include the introduction of common EU rules for third-country nationals, such as clearer deadlines for the recognition of qualifications, greater use of electronic procedures and improved access to information. Additional measures may include the establishment of approved lists of qualifications or providers from third countries meeting EU minimum training requirements, allowing for automatic recognition in selected professions.

Across all strands, the development of EU-wide digital credentials is envisaged as a key tool to simplify procedures and support more coherent recognition processes across Member States. This includes enabling professionals to share their qualifications and skills digitally, for example with employers through the EU digital identity wallet under the eIDAS Regulation.

The preparation of the initiative will be supported by three impact assessments, based on three external studies and evidence from the February 2026 implementation report on the PQD. Stakeholder input will form a central part of the evidence base for this process.

To this end, an open public consultation on the SPI was held between 5 December 2025 and 27 February 2026. The consultation – which garnered 785 replies from (primarily) individual (EU and non‑EU) citizens but also organisations (such as public authorities, academic institutions, NGOs and business associations) – revealed that the EU's current skills portability scheme is failing workers and employers alike. In particular, a large majority of respondents (67 %) considered the recognition procedures for regulated professions too lengthy, costly and complex (in particular for non‑EU nationals). Other additional factors were widely perceived to contribute to delays in mobility and create obstacles for both applicants and employers, including employers struggling to assess competences gained outside the EU, fragmentation and complexity of EU tools (such as Europass), and the limited use and portability of digital credentials. Among individuals who underwent a formal recognition procedure, outcomes were often poor, with 22 % ending up in jobs below their qualification level and 20 % being discouraged from moving to another country. By contrast, an overwhelming majority (around 90 %) expressed support for EU-level action across all proposed areas, with stakeholders divided on the need for new legislation or better implementation of existing rules.¹²

Further targeted consultations are planned, including hearings with social partners, expert workshops, focus groups, and stakeholder interviews across Member States. Case studies are also envisaged to examine specific sectoral and regional impacts.

Parliamentary resolutions

During its eighth and ninth legislative terms, the European Parliament adopted six non‑legislative resolutions relevant to the recognition of professional qualifications.

In 2017, Parliament adopted two resolutions on the topic, one on obstacles to EU citizens' freedom to move and work in the internal market, and a later one on a  new skills agenda for Europe. In the first one, Parliament called on Member States to ensure the proper functioning of the IMI, facilitating effective data exchange and administrative cooperation while avoiding unnecessary administrative burdens (paragraph 44). In the second, besides emphasising the need for more systematic use of the IMI, it called for further standardisation of academic titles and continuous education diplomas across Member States (paragraph 17).

In a resolution of January 2018, Parliament focused on the implementation of the PQD and the need for reform in professional services. Parliament welcomed the Commission's efforts in promoting convergence among Member States, but highlighted persistent differences in national regulatory approaches. It therefore called for a Commission assessment of the quality of national regulations, with a view to evaluating their overall performance in each Member State (paragraph 4).

This was followed in October 2018 by a resolution on promoting the automatic mutual recognition of diplomas, notably of higher education and upper secondary qualifications, including learning outcomes from study periods abroad. Parliament encouraged the Commission to support this objective through mutual learning and the exchange of best practices, such as statements of comparability and the consistent use of the European credit transfer and accumulation system (ECTS) grading table (paragraph 1). The resolution was issued as part of ongoing discussions between the Commission and the Council on a proposal for a Council recommendation on the topic, adopted in November 2018.

In a resolution of January 2021 on strengthening the single market and the future of free movement of services, Parliament stressed the need to improve cooperation between single points of contact, in particular through improved information exchange on national requirements and procedures. It also invited the Commission to work together with bodies such as the European Labour Authority (paragraph 43). Furthermore, in a January 2023 resolution, Parliament urged the Commission to initiate infringement procedures when Member States fail to comply with EU rules on the recognition of professional qualifications (paragraph 16).

More recently, during the current tenth legislative term, Parliament adopted a resolution in September 2025 on the implementation and streamlining of EU internal market rules to strengthen the single market. It stressed 'the need for streamlined automatic procedures and fast-track mechanisms to facilitate the recognition of professional qualifications, particularly in sectors facing labour shortages' (paragraph 21). Parliament highlighted that inefficiencies in recognition continue to create unjustified barriers to the free movement of persons and services within the internal market.

Selection of parliamentary questions

During Parliament's ninth and tenth legislative terms, Members of the European Parliament (MEPs) submitted nine written questions relevant to the PQD.

In 2020, MEP Sirpa Pietikäinen (EPP, Finland) raised concerns about the use of the word 'physiotherapy' in Annex V of Directive 2005/36/EC. In its response, the Commission stated that it had consulted Member States on the designation of this category and none had requested a change to its generic name. It also clarified that automatic recognition is based on the specific titles of qualifications listed under each category, rather than on the category label itself. An amendment via the ordinary legislative procedure was therefore not envisaged. The same issue was raised again by MEP Alex Agius Saliba (S&D, Malta) in March 2026, with the Commission reiterating that any change to the generic name in Annex V would require a legislative amendment, as it fell outside its delegated powers. It noted, however, that a systemic solution was being explored as part of the ongoing evaluation of Directive 2005/36/EC.

In 2020, MEPs Sabine Verheyen, Dennis Radtke, Ralf Seekatz and Stefan Berger (EPP, Germany) questioned the implementation of the European professional card in certain Member States, particularly where procedures exceeded the standard deadlines. The Commission noted that deadlines may be suspended where an application file is incomplete, and extended in duly justified circumstances. As a consequence, issuing an EPC may in some cases take up to five months.

Several MEPs also highlighted shortcomings in the alert mechanism. In 2021, MEP Nathalie Colin-Oesterlé (EPP, France) drew attention to delays in circulating information on disqualified professionals between Member States and called for new implementing acts to strengthen the system. The Commission did not envisage such measures at that time, but stressed it would continue to monitor implementation and, if necessary, launch infringement procedures. Similarly, in October 2025, MEP Ton Diepeveen (PfE, Netherlands) raised concerns about disqualified healthcare professionals continuing to practise in other Member States. The Commission emphasised that national authorities remain responsible for identifying such cases, and alerts transmitted through the IMI can provide an additional source of information. It also indicated that new guidance and exchanges of good practices are envisaged to improve the IMI's handling of alerts.

Further questions concerned the scope of EU action in the standardisation of health professions. In 2024, MEP Silvia Sardone (ID, Italy) suggested standardising competences across healthcare professions in the EU, including through a potential amendment to the PQD. The Commission clarified that Directive 2005/36/EC did not seek to fully harmonise training requirements, including competences, as Member States remained responsible for the organisation of their education and training systems under the Treaties. Nevertheless, certain professions might still benefit from automatic recognition based on minimum training requirements.

In October 2025, MEPs Elena Nevado del Campo and Pablo Arias Echeverría (EPP, Spain) asked whether the forthcoming SPI could support further action for healthcare professions not uniformly regulated or recognised across the EU. The Commission stated that the SPI is expected to support the modernisation and expansion of recognition processes and that it is assessing whether additional professions could meet the conditions for automatic recognition, including through common training frameworks.

Two written questions addressed updating minimum training requirements for midwives. In June 2025, MEP Adam Jarubas (EPP, Poland) raised the possibility of revising the PQD to allow midwives to obtain nursing qualifications recognised across the EU, in a similar way to nurses obtaining midwifery qualifications. The Commission replied that the 2026 implementation report would inform any possible changes, including those concerning minimum training requirements. Most recently, in February 2026, MEP Marko Vešligaj (S&D, Croatia) called for the alignment of midwifery training requirements with international standards. The Commission confirmed that an update of these requirements, through a delegated act, was under consideration for 2026.

Petitions and citizens' enquiries

The European Parliament has received a significant number of petitions on the application of the PQD during its ninth and tenth legislative terms. The most common complaint concerned administrative delays in certain Member States, with petitioners in some cases reporting prolonged waiting times, leaving professionals unable to work in their field for years.¹³ Several petitioners also reported being subjected to disproportionate compensation measures before their qualifications were accepted. A further concern was that certain professions, including forensic pathology, some medical sub-specialisations and several health technician roles, fall outside the 'sectoral' recognition system and must rely on the general regime.¹⁴ Finally, several petitions challenged national rules that reserve certain professional activities to holders of specific qualifications without sufficient public interest justification.

2019 European Parliament study on the impact on labour mobility of the revised PQD

In 2019, the Policy Department of Economic, Scientific and Quality of Life Policies acted upon the request of the European Parliament's Employment and Social Affairs Committee (EMPL) and published a study on the impact of the 2013 revision of the PQD on labour mobility and employment within the EU.

Covering the first three years after the transposition deadline of January 2016, the study was based on a relatively limited time span, but still allowed for an assessment of early effects on mobility patterns. Overall, it found that recognition procedures were not, in themselves, the main obstacle to mobility for EU professionals. Since 2011, around 85 % of recognition requests had resulted in positive decisions. However, persistent differences were identified across professions and countries of origin, with evidence that recognition-related issues had hindered access to employment abroad. More broadly, the study highlighted that recognition was not a primary driver of mobility from the country of origin perspective, although it could facilitate labour mobility and influence destination choices.

A number of structural barriers within the recognition system were also found to affect mobility in practice, broadly consistent with findings reflected in later Commission assessments (2020 and 2026). These included fragmented and complex procedures, administrative burden, costs and limited access to information.

The study provided several policy recommendations, such as improving transparency and guidance in national procedures, increasing awareness and use of EU tools (e.g. the EPC), and strengthening the functioning of the IMI system through broader involvement of competent authorities. It also called for more regular updates of Annex V to ensure that newly introduced qualifications could benefit from automatic recognition.

European Economic and Social Committee (EESC)

In April 2024, in an opinion on the services sector in the EU, the EESC called for further harmonisation of the PQD (point 1.1), highlighting the need to better align education and training systems with evolving labour market demands (point 2.6). In December 2024, the EESC adopted an opinion on the factual and legislative analysis of the integration of migration flows into the EU labour market, stressing the importance of recognising migrants' diplomas and professional qualifications. It also pointed to the potential of developing common European standards for qualifications and competences to address existing challenges (point 1.6)

Finally, in an opinion of February 2026 on the Commission's 2025 single market strategy, the EESC expressed support for simplifying procedures to recognise professional qualifications, including for third-country nationals. It raised concerns, however, about the use of self-certification mechanisms, particularly in sectors where qualifications have direct implications for health, safety and public responsibility (point 1.7).

European Committee of the Regions (CoR)

The European Committee of the Regions (CoR) issued an opinion in May 2025 on regional challenges and solutions for healthcare workers. Building on the findings of ECA's 2024 special report, it called on the Commission to strengthen the monitoring of Member States' implementation of the directive. In particular, the CoR underlined the importance of ensuring compliance with the legal deadlines for recognition procedures and improving the effective use of the alert mechanism (point 40). These issues were not specifically addressed in the Commission's follow-up of 13 March 2026 to the CoR opinion.