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Recognition of professional qualifications acquired in the United Kingdom

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

The 31 January 2020 withdrawal was followed by a transition period lasting till 31 December 2020.

The Withdrawal Agreement, together with the Trade and Cooperation Agreement, are the main instruments governing EU's relations with the United Kingdom (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 acquired (for EU nationals) or recognised (for UK nationals) before the end of the transition period.

Following Brexit, the European Commission produced operational guidelines for the recognition of professional qualifications (EN) attained in the UK. The document clearly differentiates between professional qualifications acquired in the UK by UK nationals and professional qualifications acquired in the UK by EU nationals for the purposes of both establishment and free provision of services.

In compliance with EU law, EU citizens have the right to pursue a regulated profession, either as employees or self-employed persons, in a Member State other than the one in which they acquired their qualifications.

 In this context, EU citizens enjoy specific procedural and substantive rights regarding the recognition of their qualifications by an EU country other than the one where they were acquired (Directive 2005/36/EC).

Depending on the profession, different recognition regimes may apply. For some, such as lawyers and statutory auditors, specific rules may apply.

In general, the EU regime does not apply to the recognition of professional qualifications held by third-country nationals, except for existing specific provisions, e.g. those for Swiss nationals and European Economic Area (EEA) nationals.

Italy extends Directive 2005/36/EC to qualifications acquired in third countries by implementing Articles 39, 49 and 50 of Presidential Decree 394/99 as subsequently amended and/or integrated, with some additional formalities in terms of documentation to be submitted and in relation to the application of any compensatory measure.

As a general rule, qualifications acquired by EU nationals in the UK before 1 January 2021 are, for all intents and purposes, EU qualifications.

The rules and recognition regimes set out in Directive 2005/36/EC apply to the recognition of such qualifications for all types covered therein (educational qualifications; professional experience; certificates of competence) and without any time limit.

Upon conclusion of the transitional period, UK citizens are third-country nationals within the EU. This means that they can no longer rely on the EU regime for the recognition of professional qualifications. For more information on the recognition of UK qualifications held by UK nationals, please read the European Commission's note on the rights of EU and UK nationals, as outlined in the Withdrawal Agreement.

Recognition of professional qualifications
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