UK-EU TCA: professional qualifications
This briefing explains what has changed for UK qualified professionals who seek to practice in the EU market and vice versa. It summarises the provisions in the Agreement under which the UK and EU can come to sector-by-sector mutual recognition arrangements in the future.
Recognition of professional qualification (RPQ) is a system which allows professionals qualified in one country to practice in another, with limited administrative requirements and without having to requalify. This is particularly relevant for regulated professions, such as medics, architects, lawyers or statutory auditors who seek to establish in, or export their services to, another country.
From 1 January 2021, EU rules with regard to professional qualifications no longer apply to the United Kingdom, and mutual recognition of professional qualifications has ended. UK qualified workers wishing to work in the EU have to meet the qualification requirements of each individual EU Member State, i.e. the principle of “host-country rules” applies. The same is true for EU qualified workers seeking recognition of their qualifications in the UK: they have to comply with UK rules on professional qualifications.
The UK and EU Trade and Cooperation Agreement (TCA) includes limited commitments on RPQ. The Agreement states that both sides will seek to establish more detailed reciprocal arrangements on a sector-by-sector basis in the future. The government has said that arrangements with EU Member States’ regulators outside the TCA-provisions would be possible. It is not clear if this refers to bilateral or EU-wide arrangements.
The UK has temporarily retained most of the former framework of recognition of professional qualifications acquired in the EEA and Switzerland as it was at the end of the transition period. On 12 May 2021, the government introduced the Professional Qualifications Bill in Parliament setting out a new UK framework.