While the UK was a member of the EU, professional qualifications obtained in any EEA country or Switzerland were part of a reciprocal system which allowed nationals of those countries to have their qualifications recognised throughout the EEA or Switzerland, enabling them to practise their profession across Europe.
That system was based on an EU Directive which ceased to apply in the UK with effect from 11pm on 31 December 2020. As part of the EU withdrawal arrangements, it was agreed that qualifications that had already been recognised before that date and recognition applications already in progress on that date would continue to be dealt with under the previous rules.
However, from 1 January 2021, the UK has put in place a New Temporary General System for the recognition of professional qualifications. Whilst in many respects this provides continuity with the previous rules, it also introduces a number of significant changes:
- The UK will only grant recognition to qualifications that are comparable in scope, level and content to a UK qualification. So, for example, recognition may not be granted where:
- the professional training required or received is substantially different from that in the UK; or
- the profession in the UK does not have a single corresponding profession in the relevant country from which the applicant comes.
- The following are no longer part of the general system and the UK will make separate legislation for them regarding the recognition of qualifications:
- most medical, health and social care professionals;
- architects, vets, farriers, statutory auditors, notaries and lawyers; and
- teaching professionals.
- Regulatory bodies in the EEA/Switzerland and the UK are no longer under an obligation to co-operate with each other regarding applications submitted after 31 December 2020. UK regulatory bodies will no longer receive alerts regarding the fitness to practise or professional standing of individuals via the Internal Market Information system. However, the sharing of information between regulatory bodies in the UK and EEA/Switzerland about criminal sanctions or disciplinary action against individual applicants is still permitted upon request.
- There is no longer an obligation on UK regulatory bodies to consider applications for partial access to a profession or for temporary or occasional services, except in the case of Swiss nationals for whom the UK has agreed an extended transitional period of up to 5 years.
- UK professional bodies are only obliged to consider applications in relation to EEA or Swiss qualifications; they are no longer obliged to consider non-EEA or Swiss qualifications, even if held by an EEA or Swiss national.
- New applications for European Professional Cards will not be possible.
On a practical level, employers, individuals and professional regulatory bodies can still seek advice and assistance from the National Recognition Information Centre for the United Kingdom (UK NARIC).
Note that the recognition of a qualification by the UK does not grant the right to work in the UK, as that must be obtained by following the appropriate immigration procedure.