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Internal Market, Industry, Entrepreneurship and SMEs

Recognition of professional qualifications acquired in the United Kingdom by European Union nationals

The withdrawal of the United Kingdom (UK) from the European Union (EU), commonly referred to as Brexit, has had consequences on the recognition of professional qualifications acquired in the UK.

The UK’s withdrawal took place on 31 January 2020. A transition period followed which lasted until 31 December 2020. The Withdrawal Agreement, along with the Trade and Cooperation Agreement, are the primary instruments governing the EU's relationship with the UK.

The implications on the recognition of professional qualifications depend on whether it is an EU or a UK national holding the qualification and whether the qualification was obtained (for EU nationals) or recognised (for UK nationals) before the end of the transition period.

Under EU law, EU citizens have the right to pursue a regulated profession, on an employed or self-employed basis, in an EU country other than the one in which they obtained their qualification. In that context, EU nationals have specific procedural and substantive rights regarding the recognition of their qualifications by an EU country different from the one where they acquired their qualifications (see Directive 2005/36/EC).

Depending on the profession, different recognition regimes may apply. Specific rules may apply to some professions, such as lawyers and statutory auditors.

In general, this EU regime does not apply to the recognition of professional qualifications held by non-EU nationals, unless specific arrangements are in place, e.g. for Swiss nationals and nationals of the European Economic Area (EEA).

As a general rule, qualifications obtained in the UK before the end of the transition period set out in the Withdrawal Agreement (before 1 January 2021) by EU nationals are EU qualifications. The rules and recognition regimes of Directive 2005/36/EC apply to the recognition of these qualifications.

This is valid for all types of qualification covered by Directive/2005/36/EC, meaning evidence of formal qualifications, professional experience and attestations of competence. Furthermore, it applies to all recognition regimes of the directive, with no limitation in time.

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