135 submissions from 117 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 359 submissions on this file. Shown here: the 135 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
19 submissions from industry — companies and their trade associations — against 26 from civil society: NGOs, consumer organizations, environmental groups and trade unions.
Industry 19Civil society 26Public authorities, academia, other 90
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
The file, right now
The consultation closed on 23 Jun 2026 — it ran from 26 May 2026.
Policy area
Employment (DG EMPL)
Where it stands
Awaiting adoption
Adoption expected
30 Sept 2026 · in 31 days
How it got here
Call for evidence24 Mar 2026
Dir del draft23 Jun 2026
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Dir del.
The Malta Association of Physiotherapists and the University of Malta Physiotherapy Department have jointly reviewed the draft delegated directive establishing a Common Training Framework (CTF) for physiotherapists. The following points reflect the matters we consider most decisive for ensuring that the framework is educationally credible and protects patient safety. 1.
Position of the Scientific Society for Invasive Physiotherapy and Acupuncture on the draft Delegated Directive of the European Commission establishing a Common Training Framework for Physiotherapists The Scientific Society of Invasive Physiotherapy and Acupuncture (SCFIA), part of the Spanish Association of Physiotherapists (AEF), expresses its support for the observations and proposals made by the AEF in relation…
Filed in Spanish · English published by the European Commission
I echo the points and concerns raised by the Irish Society of Chartered Physiotherapists, including sub groups of the ISCP, in particular those representing physiotherapists working in neurology and gerontology. I also support the feedback submitted by educational institutions in Ireland including those submitted by UCD for example.
The Faculty of Nursing and Physiotherapy of the University of the Balearic Islands (Spain) appreciates the opportunity to submit comments on the draft Commission Delegated Directive establishing a Common Training Framework (CTF) for the profession of physiotherapist.
Position Statement of Chartered Physiotherapists in Rheumatology (CPR), Irish Society of Chartered Physiotherapists (ISCP), on the Proposed European Common Training Framework (CTF). Whilst the CPR supports professional mobility, we do not support the current draft of the CTF. The physiotherapy profession in Ireland has moved far beyond a technical or supportive role.
Position Statement of Secretary of Chartered Physiotherapists in Management (CPM), Irish Society of Chartered Physiotherapists (ISCP), on the Proposed European Common Training Framework (CTF) for Physiotherapy Chartered Physiotherapists in Management (CPM), the employment subgroup of the Irish Society of Chartered Physiotherapists (ISCP), supports initiatives that facilitate professional mobility across the European…
To the European Commission, Faculty of Health and Social Sciences at the Western Norway University of Applied Sciences (HVL) has given feedback in the attached letter. Yours sincerely [name removed] Senior Adviser Faculty of Health and Social Sciences Western Norway University of Applied Sciences
Summary position of the VLL (see attached file for details) The VLL supports the introduction of a CTF at EQF level 6 and is in favour of full academisation in the future. At the same time, we call for binding transitional arrangements for vocational schools and see an urgent need for reform of the current professional law.
Filed in German · English published by the European Commission
The Faculty of Nursing and Physiotherapy of the University of Lleida welcomes the opportunity to provide comments on the draft Commission Delegated Directive establishing a Common Training Framework (CTF) for the profession of physiotherapist. We appreciate the extensive consultation process undertaken by the European Commission and support several key elements of the proposal.
General comments It Is crucial that Physiotherapy education is at university level and at least EQF level 6 and minimum 180 ECTS. Nevertheless, we are concerned that introduction of CTF for physiotherapists will contribute to lowering the standard and quality of physiotherapy through this common framework, and that it will be an obstacle for professional development in physiotherapy across countries.
In principle, the Turku University of Applied Sciences supports the objective of increasing and facilitating the mobility of students and professionals in Europe. We also see the improvement of the comparability of trainings as a good thing.
Filed in Finnish · English published by the European Commission
The Royal Dutch Society for Physical Therapy (KNGF), also on behalf of the Dutch Association for Quality in Physical Therapy (Stichting Keurmerk Fysiotherapie, SKF), supports European cooperation and the mobility of healthcare professionals. However, mobility must never come at the expense of the quality of care and patient safety.
POSITION PAPER ON SAFEGUARDING HIGH EDUCATIONAL STANDARDS AND PATIENT SAFETY WITHIN THE PROPOSED COMMON TRAINING FRAMEWORK FOR PHYSIOTHERAPISTS Submitted by: Aurora María Araujo Narváez Dean of the Professional College of Physiotherapists of the Community of Madrid Madrid, Spain June 2026 INTRODUCTION The Professional College of Physiotherapists of the Community of Madrid (Spain), a public-law professional…
Physio Austria welcomes the development of a European Common Training Framework (CTF) for Physiotherapy. In our view, the proposed framework represents a logical continuation of the harmonisation efforts initiated through the ESCO project and provides a transparent and coherent basis for the comparability of physiotherapy qualifications and consistent recognition procedures across Europe.
South-Eastern Finland University of Applied Sciences (Xamk) supports the establishment of a common training framework for physiotherapy education, the promotion of mobility, and the definition of the minimum level of education at EQF level 6.
Subject: Feedback on the proposed Common Training Framework for physiotherapists under Directive 2005/36/EC The Icelandic Physiotherapy Association welcomes the European Commissions objective of supporting professional mobility and efficient recognition procedures.
On behalf of Oslo Metropolitan University, dep. Rehabilitation Science and Health Technology we would like to give the following feedback on the Common Training Framework (CTF) draft: The proposed Common Training Framework defines a set of end level competencies for physiotherapists, including clinical reasoning and evidence-based practice.
While professional mobility across Europe is important, it should not come at the expense of patient care. I do not support Ireland's participation in the proposed Common Training Framework (CTF) in its current form.
The IFK thanks for the opportunity to comment on the European Commission’s draft delegated act establishing a common training framework (CTF) for the profession of physiotherapist. The Federal Association of Self-Employed Physiotherapists (IFK e.V.) has been active as a professional association for its members since 1981.
Filed in German · English published by the European Commission
Physio Deutschland supports the full academicisation of Physiotherapy and welcomes the opportunity to comment on the draft delegated act for the Common Training Framework. We strongly support the establishment of a high qualification standard at a minimum of EQF level 6. In our view, this is essential to ensure modern, safe, evidence-based, and comparable physiotherapy care across Europe.
Filed in German · English published by the European Commission
The Department of Physiotherapy of the University of Alcalá welcomes the opportunity to contribute to the consultation on the proposed Common Training Framework (CTF) for Physiotherapists. As the academic unit responsible for the delivery, coordination and quality assurance of approximately 80 % of the curriculum of the Bachelors Degree in Physiotherapy at the University of Alcalá, we wish to provide comments from…
Filed in Spanish · English published by the European Commission
We, Institute of physiotherapy at Saint Joseph University of Beirut- Lebanon, support a Common Training Framework for physiotherapists, but only one that raises standards. The 180 ECTS minimum should be defined as a floor for recognition only, with movement towards at least 240 ECTS at EQF level 6, delivery through higher education, robust supervised clinical education, a transparent quality assurance mechanism, and…
Position Statement: The Panhellenic Physiotherapists Association (PSF) on the Common Training Framework As a physiotherapist working in Greece, I strongly support the position statement of Panhellenic Physiotherapists' Association The Panhellenic Physiotherapists Association (PSF) is the sole professional organization representing chartered physiotherapists in Greece.
As a chartered physiotherapist in the republic of Ireland, I have real concerns regarding the Autonomy of practice across European countries. The scope of physiotherapy practice is not the same across Europe. It is defined at national level to reflect the needs of each country's healthcare system and population.
Position Statement: The Panhellenic Physiotherapists Association (PSF) on the Common Training Framework As a physiotherapist working in Greece, I strongly support the position statement of Panhellenic Physiotherapists' Association The Panhellenic Physiotherapists Association (PSF) is the sole professional organization representing chartered physiotherapists in Greece.
Consultation response from the Department of Health and Care Sciences, Bachelors and Masters in Physiotherapy Department of Health and Care Sciences at The Arctic University of Norway hereby sends its consultation response in regard to supplementing Directive 2005/36/EC.
The Finnish Association of Physiotherapists (FAP) welcomes the opportunity to comment this draft. FAP supports the goal of promoting professional mobility within the EU. It also agrees with setting EQF Level 6 as the minimum qualification level and recognizes positive elements in the proposal, such as the emphasis on professional autonomy and minimum clinical training requirements.
We fully recognize and respect that each of our member institutes operates within its own national or local context and may hold its own distinct position on this matter. ENPHE's advocacy is intended to support the field, but it is not meant to override or conflate the specific positions held by your institutions.
As a Professor in Physiotherapy in Greek University and also member of Quality Assurance Committee of University of Thessaly, I strongly support the position statement of Panhellenic Physiotherapists' Association The Panhellenic Physiotherapists Association (PSF) is the sole professional organization representing chartered physiotherapists in Greece.
Position Statement: The Panhellenic Physiotherapists Association (PSF) on the Common Training Framework As a physiotherapist working in Greece, I strongly support the position statement of Panhellenic Physiotherapists' Association The Panhellenic Physiotherapists Association (PSF) is the sole professional organization representing chartered physiotherapists in Greece.
Demand for physiotherapy services is rising due to ageing populations, chronic disease and rehabilitation needs. A common training framework built on existing similarities in how participating countries regulate, educate and train professionals would allow automatic cross-border recognition of qualifications.
Filed in Italian · English published by the European Commission
The Spanish Association in Higher Education welcomes the opportunity to provide comments on the draft Commission Delegated Directive establishing a Common Training Framework (CTF) for the profession of physiotherapist.
Position Statement: The Panhellenic Physiotherapists Association (PSF) on the Common Training Framework The Panhellenic Physiotherapists Association (PSF) is the sole professional organization representing chartered physiotherapists in Greece. While the PSF welcomes and supports the development of the Common Training Framework, we firmly believe that essential modifications are required.
The UK is indirectly affected by the proposed EU Directive and therefore our position should not be interpreted as either support for or opposition to the establishment of a Common Training Framework (CTF). Rather, our primary concern is whether the draft framework establishes a sufficiently robust, precise, and future focused minimum standard for contemporary physiotherapy practice.
The Founding Committee of the National Academy of Physiotherapy of Spain (ANFiE) welcomes the opportunity to comment on the proposed CTF for physiotherapists. We support the objective of facilitating professional mobility across Europe while maintaining high standards of education, competence and patient safety.
As the Messinia & Lakonia Regional Section of the Panhellenic Physiotherapists' Association, representing 158 members, we strongly support the position statement of the Panhellenic Physiotherapists' Association.
As the Larissa Regional Section of the Panhellenic Physiotherapists' Association, representing 341 members, we strongly support the position statement of the Panhellenic Physiotherapists' Association. Position Statement: The Panhellenic Physiotherapists' Association (PSF) on the Common Training Framework The Panhellenic Physiotherapists' Association (PSF) is the sole professional organization representing chartered…
As the Regional chairman of Western Crete (Chania - Rethymnon ) Physiotherapists, Regional Section of the Panhellenic Physiotherapists' Association, representing 300 members, We strongly support the position statement of the Panhellenic Physiotherapists' Association.
Typical EU, more legislation formulated by unelected bureaucrats as they push further towards their end goal of federalisation. To hell with professional standards and duty of care! If you want this to work, raise the standard for every country. Set the new highest standard, don't lower it.
As the Lesvos Chios Samos Regional Section of the Panhellenic Physiotherapists' Association, representing 185 members, we strongly support the position statement of the Panhellenic Physiotherapists' Association.
The Paediatric Physiotherapy Section of the Spanish Association of Physiotherapy (AEF-Ped) welcomes the European Commissions initiative to establish a Common Training Framework (CTF) to facilitate professional mobility and improve comparability of physiotherapy qualifications across Member States.
EQF level and duration of training to access the title of physiotherapist Proposed change to paragraph 1 of Article 4 - Minimum qualification level to benefit from automatic recognition, As a regulatory authority the Ordem dos Fisioterapeutas aims to protect the public and the national legislation states that the education of physiotherapists is based on the bologna first cycle, with a four-year education (240…
As the Serres Regional Section of the Panhellenic Physiotherapists' Association, representing .150 members, we strongly support the position statement of the Panhellenic Physiotherapists' Association. Position Statement: The Panhellenic Physiotherapists Association (PSF) on the Common Training Framework The Panhellenic Physiotherapists Association (PSF) is the sole professional organization representing chartered…
Position Statement: The Panhellenic Physiotherapists Association (PSF) on the Common Training Framework The Panhellenic Physiotherapists Association (PSF) is the sole professional organization representing chartered physiotherapists in Greece. While the PSF welcomes and supports the development of the Common Training Framework, we firmly believe that essential modifications are required.
The Association for Physiotherapy Association for Physiotherapists (VPT) e.V. represents the professional interests of physiotherapists and their political voice. The VPT warmly welcomes the European Commission’s initiative to introduce a common European training framework (CTF) for physiotherapists.
Filed in German · English published by the European Commission
The National Chamber of Physiotherapists recognize the need to establish the CTF as a tool that supports ensuring a comparable level of qualifications and facilitates the free movement of professionals. At the same time, we present the following comments and 6. proposals: 1. Minimum ECTS level the need to raise standards.
The United Services Trade Union (ver.di) is in principle in favour of introducing a common training framework/common training framework (CTF) for physiotherapists in the European Union (EU). A CTF is an important step to further strengthen the free movement of physiotherapists within the EU. This requires that the diversity of education systems across the EU is fully taken into account.
Filed in German · English published by the European Commission
My concerns regarding the proposed CTF are: 1. Risk of a downward harmonisation of standards Ireland's four-year honours degree is at the higher end of European entry-level programmes. Across Europe, entry-level education ranges from 3 to 5 years with programmes awarding either a diploma, Bachelor's, or Master's degree.
The Croatian Council of Physiotherapists has been involved from the beginning in the development of the European Common Qualification Framework (CTF) for physiotherapists and in the dialogue with national authorities and our educational institutions. This draft CTF proposal is based on expert assessments of what is needed to ensure quality, patient safety and mobility.
Physiotherapy is an autonomous healthcare profession that requires extensive theoretical knowledge, clinical reasoning, and substantial clinical practice. A 240 ECTS programme is necessary to ensure graduates achieve the competencies required for safe and independent practice, while 180 ECTS may be insufficient to provide the depth and breadth of education expected of contemporary physiotherapists.
I believe physiotherapists should have a minimum of 240 ECTS credits to ensure consistent professional competence. Ideally, the common training framework should require a Level 7 (Master's degree) qualification to promote high-quality care and easier recognition of qualifications across countries.
The Spanish Association of Physical Therapists in Mental Health appreciates the opportunity to provide feedback on the draft Commission Delegated Directive establishing a Common Training Framework (CTF) for the profession of physical therapist. We acknowledge the extensive consultation process conducted by the European Commission and welcome several key elements of the proposal.
I completely agree and believe that 180 ECTS credits are merely the minimum requirement for recognition, not a national educational benchmark subject to a guarantee against regression. It is essential to aim for a general threshold of no less than 240 ECTS credits at EQF Level 6, while also respecting and promoting longer study programs that correspond to EQF Level 7.
The Fachbereichstag Therapiewissenschaften (FBTT) is the collegial body of academic self-governance of (study) deans and heads of degree programmes at universities of applied sciences (currently n=19) and universities (currently n=6) offering degree programmes in the professions of occupational therapy, speech and language therapy, and physiotherapy.
As the National Representative for Iceland in ENPHE, I support the goal of facilitating professional mobility across Europe. I also support a Common Training Framework (CTF) for physiotherapistsbut only one that raises educational standards.
The Hochschulverbund Gesundheitsfachberufe e.V. (HVG) [University Association for Healthcare Professions] stands for full university education in the therapeutic professions and hereby takes the opportunity to formulate a position on the European Commission’s draft legal act.
Filed in German · English published by the European Commission
I submit this opinion in my capacity as ENPHE Coordinator for the National Sports Academy "Vassil Levski" (NSA), Bulgaria. The National Sports Academy supports the position of ENPHE regarding the development of a Common Training Framework for Physiotherapists. This position reflects the views of the academic community and is supported by the university leadership.
While the French National Council of the Order of Physiotherapists (Conseil national de lordre des masseurs-kinésithérapeutes CNOMK), through the organisation of an event endorsed by the French Presidency of the Council of the European Union (PFUE) during the first half of 2022 and through the facilitation of working groups over several months on this topic, has supported the work undertaken by the European…
The DSV warmly welcomes the European Commission’s initiative to introduce a common European training framework for physiotherapists (CTF) and the corresponding presentation of the draft delegated directive. This approach can simplify and speed up recognition procedures for physiotherapists and facilitate access for qualified foreign professionals to the respective European health systems, including the German health…
Filed in German · English published by the European Commission
Renu Physiotherapy, based in Ireland would like to voice our concerns regarding the proposed EU Common Training Framework (CTF). As a member of the Irish Society of Chartered Physiotherapists (MISCP) we agree with the concerns raised regarding this proposal. Physiotherapy education, scope of practice, and levels of clinical autonomy vary considerably across Europe.
Uppsala University shares the concerns expressed by LTU regarding Article 5(1)(b), which requires a minimum of 1,000 hours of clinical training with direct patient contact. While the Common Training Framework clearly defines the expected knowledge, skills, and competences, recognition should be based on these learning outcomes rather than fixed input requirements.
Satakunta University of Applied Sciences would like to thank you for the opportunity to provide its comments. We support the development of a shared education framework and the promotion of professional mobility within the European Union. We also endorse setting the minimum level of education at EQF Level 6, which in many Member States corresponds to higher education qualifications.
I am Sonia Monterde Pérez, coordinator of the Physical Therapy degree in Universitat Rovira I Virgili (URV), URV welcomes the opportunity to provide comments on the draft Commission Delegated Directive establishing a Common Training Framework (CTF) for the profession of physiotherapist.
The Order of Physiotherapists in Romania welcomes the opportunity to provide comments on the draft Commission Delegated Directive establishing a Common Training Framework (CTF) for the profession of physiotherapist. We welcome the European Commissions efforts to improve mobility and comparability of professional qualifications across Europe. We recommend strengthening the following areas: 1.
We are commenting from the perspective of the Institute of Rehabilitation and Social Services at Jyväskylä University of Applied Sciences. We are one of the universities of applied sciences in Finland that offers physical therapy education. In general, we support the development of common competency requirements that promote, among other things, the mobility of the European workforce.
I am professor of clinical nutrition and dietetics and have worked closely with physiotherapy colleagues for more than 30 years. I fully understand the concerns of my professional colleagues, other healthcare professionals and those requiring physiotherapy assessment and management in Ireland regarding the proposed Common Training Framework.
AEF Geriatrics and Gerontology Affiliated Society (AEF GyG) On behalf of our AEF GyG Affiliated Society, we would like to express our appreciation for the opportunity to contribute to the consultation process regarding the draft Delegated Directive establishing a Common Training Framework (CTF) for the profession of physiotherapist in the European Union.
The Spanish Association of Physiotherapy Managers (AEF-SEDIF) welcomes the opportunity to provide comments on the draft Commission Delegated Directive establishing a Common Training Framework (CTF) for the profession of physiotherapist. We appreciate the extensive consultation process undertaken by the European Commission and support several key elements of the proposal.
The Bulgarian Association of Physiotherapists does not agree with the suggested duration of training in the proposed version of the Common Training Framework for Physiotherapist. It lacks sufficient guarantees for the quality and development of the profession at international and national levels. We strongly believe that the minimum required level of training should be 240 ECTS.
The Slovenian Association of Physiotherapists (Združenje fizioterapevtov Slovenije ZFS) welcomes the European Commissions initiative to establish a Common Training Framework for physiotherapists. We strongly support the noble ambition of facilitating professional mobility and strengthening the European dimension of physiotherapy.
Input from the Norwegian Physiotherapist Association (NPA) The Norwegian Physiotherapist Association (NPA) has followed the development of a European Common Training Framework (CTF) for physiotherapists in dialogue with national authorities and the wider sector. This input is based on professional assessments of what is necessary to ensure quality, patient safety and mobility.
The Spanish Association of Physiotherapists in Women's and Pelvic Health (AEF-SAMU) welcomes the opportunity to contribute to the consultation on the proposed Common Training Framework (CTF) for physiotherapists and supports its overall objective of facilitating professional mobility across Europe.
The Aposta pel Canvi Catalonia welcomes the opportunity to comment on the draft Commission Delegated Directive introducing a Common Training Framework (CTF) for the physical therapy profession. We recognize the considerable effort undertaken by the European Commission throughout the consultation process and appreciate several important aspects of the proposed framework.
I have significant concerns regarding patient safety, quality of care and the need for competence-based equivalence across Member States (MS). The proposed CTF relies heavily on minimum training content, ECTS credits and broad descriptors of professional autonomy. These measures do not adequately demonstrate equivalence in the knowledge, skills and competences required for safe and effective physiotherapy practice.
UNIFY ČR welcomes the efforts to harmonise physiotherapy education across the European Union and supports the principle of automatic recognition of qualifications. However, several aspects of the draft require clarification and revision to ensure that harmonisation does not reduce the quality of physiotherapy education or professional practice in Member States.
Having been a physiotherapist for over 15years, I have had the opportunity to work as a physiotherapist in different settings and different countries. This has allowed me to work with physiotherapists from different backgrounds- some of which were qualified physiotherapists in their country but could not gain recognition in the country they were currently working.
As a private practice owner I share the concerns of the Irish Society of Chartered Physiotherapists about the new framework. I am familiar with applications from physios who do not fulfill the skills and professional autonomy necessary to work in this clinic. There are significant differences in anatomical knowledge , mentoring, scope of practise and clinical autonomy between EU member countries.
As a manager of an acute physiotherapy service is is vital that Physiotherapists working on my team are able to diagnose, construct treatment plans independently and treat a wide variety of conditions independently and competently. This would include cardio-respiratory conditions encompassing critical care and acute & rehabiltative neurological input.
I have serious concerns regarding the proposed EU common training framework. As a Physiotherapist manager working in care of the older adult and particulary in specialised dementia services I note that one of the core clinical areas not consistently included in training across Europe is Neurology.
I support the concerns outlined by the Irish Society of Chartered Physiotherapists regarding the proposed Common Training Framework for physiotherapy. As a private practice physiotherapist and clinic owner in Ireland, I fully support professional mobility across Europe. Good physiotherapists should be able to move, work and contribute across different countries and healthcare systems.
The proposed CTF does not allow for the variance in education and training standards within the EU. The effect if will have on private practice is that we will be trying to recruit high quality, competent physiotherapists from a cohort who do not meet the skills and professional autonomy necessary to work in Ireland, Hence we will not be suitable to fulfil workforce needs in Ireland.
Donnybrook Sports Medicine is a private physiotherapy clinic in Ireland. The currently proposed CTF would negatively impact the service which physiotherapists working in the EU can deliver. We welcome the mobility of labour and a diverse workforce within the EU and Ireland.
As a manager and Member of the Irish Society of Chartered Physiotherapists (MISCP), I am formally opposing the proposed Common Training Framework. While I support the spirit of professional mobility, I have significant concerns regarding the potential impact on clinical standards and patient safety.
I am a physiotherapist practising in Ireland and I wish to submit feedback in opposition to the European Commission's proposed delegated act establishing a Common Training Framework (CTF) for physiotherapy. While I support the principle of European professional mobility, I have serious concerns about the impact this proposal would have on patient safety and standards of care in Ireland.
The Scientific Association of Physiotherapists of Galicia (SOGAFI) welcomes the opportunity to provide comments on the draft Commission Delegated Directive establishing a Common Training Framework (CTF) for the profession of physiotherapist. We appreciate the extensive consultation process undertaken by the European Commission and support several key elements of the proposal.
The Spanish Society for Ultrasound Imaging in Physiotherapy (SEEFi) welcomes the opportunity to provide comments on the draft Commission Delegated Directive establishing a Common Training Framework (CTF) for the profession of physiotherapist. We appreciate the extensive consultation process undertaken by the European Commission and support several key elements of the proposal.
Hi there, as a private practice physiotherapy owner, I am very much in favour and support professional mobility across Europe. It is critical for our profession. That withstanding, I think the current proposal raises significant concerns. In particular, I am deeply concerned that it is exposed on the differences in education, scope of practice and levels of clinical autonomy between countries.
Physiotherapist's working in Ireland have their qualifications assessed by CORU-our regulations board, established to protect the public by ensuring that health and social care professionals meet strict standards of education, training, and professional conduct. In Ireland we are direct access practitioners who are autonomous in assessment, treatment and management of our patients.
I am a clinical specialist physiotherapist working in a regional trauma hospital in the HSE in Ireland. I have significant concerns regarding patient safety and professional standards with this proposed framework. In Ireland, cardiorespiratory and neurology are essential areas for clinical skills for all hospital and non hospital physiotherapists.
I do not support the current format of the CTF for the following reasons: Physiotherapist's working in Ireland have their qualifications assessed by CORU-our regulations board, established to protect the public by ensuring that health and social care professionals meet strict standards of education, training, and professional conduct. There would be a variability in standard or training across the EU.
We respectfully urge the inclusion of explicit competencies relating to planetary health and sustainability within the proposed European Common Training Framework (CTF) for Physiotherapists. Climate change, biodiversity loss, and pollution are increasingly recognised as major threats to human health and health system resilience, including across Europe and within physiotherapy practice [1,2].
I am a physiotherapist and postdoctoral researcher working in Ireland. While I support professional mobility and collaboration across Europe, I do not support the proposed Common Training Framework for physiotherapists in its current form due to concerns regarding patient safety, clinical competence, and public protection.
Physiotherapy training varies enormously across Europe unlike Irish graduates, many EU-trained physiotherapists are not taught to independently assess, diagnose, or treat patients, or to recognise red-flag symptoms (such as signs of cancer) that require urgent medical referral. My preference is that the current process for EU entry to physiotherapy in Ireland via the CORU regulatory body remains.
I am a Physiotherapy Practice Tutor working in a large teaching hospital and involved in the education of physiotherapy students. I have serious concerns about the CTF as Physiotherapists in Ireland are trained to be autonomous professionals, across the areas of neurology,rehabilitation,cardiorespiratory and musculoskeletal.
I have concerns regarding the proposed common framework for physiotherapist across Europe. while harmonization is a positive goal, there are significant differences in educational standards, clinical placements, scope of practice , and competency levels between countries.
Concerning: AIFI position on the Draft Delegated Act for the Common Training Framework (CTF) for physiotherapists Data: 8 June 2026 source: Official EU public consultation feedback from Belgium and the Netherlands 1. Background: The European Commission is finalising the Common Training Framework (CTF) for physiotherapists, with the aim of introducing automatic recognition of qualifications between Member States.
Filed in Italian · English published by the European Commission
I do not support the Common Training Framework (CTF) in its current form. As an internationally qualified physiotherapist currently working in Ireland, I believe it is essential to maintain high standards of physiotherapy education, professional competence, and clinical practice across all areas of the profession. This is critical to ensuring safe, effective, and evidence based patient care.
AEF-Cardio welcomes the opportunity to contribute to the public consultation regarding the draft Commission Delegated Directive establishing a Common Training Framework (CTF) for the profession of physiotherapist.
The Spanish National Conference of Deans of Faculties of Physiotherapy (CNDFF) welcomes the opportunity to comment on the draft Commission Delegated Directive establishing a Common Training Framework (CTF) for physiotherapists. We appreciate the extensive consultation process and support several key elements of the proposal.
The Irish Society of Chartered Physiotherapists (ISCP) welcomes the opportunity to provide feedback. The ISCP supports professional mobility within Europe. However, it does not support automatic recognition through the proposed Directive in its current form.
The Swedish Association of Physiotherapists is in favour of automatic recognition provided that it is patient-safe, does not undermine education and training and continues to mean that competent authorities issue the recognition. We would prefer the outline objectives of the training to be described rather than lists being drawn up indicating more specific topics.
Filed in Swedish · English published by the European Commission
We would like to highlight our concerns regarding the proposed Common Training Framework (CTF) and the implications for its implementation in Ireland. The main issue is the common competency level would be far less stringent than what is required in Ireland. There are 85 standards of proficiency listed by CORU as a requirement for physiotherapy registration, this is more than is required under the CTF.
ONCO-AEF welcomes the opportunity to contribute to the consultation on the draft Commission Delegated Directive establishing a Common Training Framework (CTF) for the profession of physiotherapist. We would also like to express our appreciation for the extensive work undertaken by the European Commission and for the broad involvement of stakeholders that has informed the development of this proposal.
The Spanish Association of Occupational Physiotherapy and Ergonomics (AEFITE )welcomes the opportunity to provide comments on the draft Commission Delegated Directive establishing a Common Training Framework (CTF) for the profession of physiotherapist. We appreciate the extensive consultation process undertaken by the European Commission and support several key elements of the proposal. : 1.
I am a clinical specialist physiotherapist working in Ireland. I trained in Northern Ireland and had to get my qualification validated prior to working in the Republic of Ireland. It was a lot of work at the time but I could understand why the validation process had to be done. The common training framework is a good idea in theory, however I have a lot of concerns about it.
As a senior musculoskeletal physiotherapist working in an acute hospital, I support efforts to improve professional mobility across Europe. However, I have concerns that the proposed Common Training Framework (CTF) does not fully reflect differences in autonomy, competence, and scope of practice across Member States.
As Physiotherapist Manager In-Charge III in a large acute teaching hospital in Dublin, with responsibility for recruitment, workforce planning, student education, and service quality, I strongly oppose the introduction of the proposed EU Common Training Framework (CTF) for physiotherapy.
Tampere University of Applied Sciences provides the following comments on the draft Common Training Framework (CTF) for physiotherapists from the perspective of a physiotherapy educator. Tampere University of Applied Sciences generally supports the development of a common training framework for physiotherapists, as it promotes the free movement of professionals between countries.
I oppose the Common Training Framework and call on Ireland to opt out on the grounds of patient safety, protection of the public and professional standards of physiotherapy because: -Autonomy varies across countries: Not all physiotherapists are trained to work at the same level of autonomy, which may affect patient safety and quality of care.
I do not agree with this initiative. It will change the value of physiotherapists in Ireland. There has been lots of money, effort and time put into protecting the title of physiotherapist in Ireland. This has served the public so that people know that when someone is registered, they can expect a certain standard of treatment.
The Dutch Federation for Physiotherapy Education (SROF), representing physiotherapy education programmes in the Netherlands, endorses the importance of European cooperation within physiotherapy education and supports initiatives that promote transparency, quality, and professional mobility. Compared to earlier versions, the current draft guideline for a Common Training Framework (CTF) shows improvements.
Laurea University of Applied Sciences (UAS) provides the following comments on the draft Common Training Framework (CTF) for physiotherapists from the perspective of a physiotherapy educator. Laurea UAS generally supports the development of a Common Training Framework for physiotherapists, as it facilitates the free movement of professionals across countries.
Comments from Luleå University of Technology (LTU) on the Draft Delegated Directive Establishing a Common Training Framework for Physiotherapists. Luleå University of Technology (LTU) supports the overall objective of facilitating professional mobility within the European Union and welcomes the recognition of physiotherapy as a higher education profession at EQF level 6.
"The Spanish Association of Physiotherapists in Primary Care and Community Health (AEF-APySC) welcomes the opportunity to comment on the draft Commission Delegated Directive establishing a Common Training Framework (CTF) for physiotherapists. We appreciate the extensive consultation process and support several key elements of the proposal.
I oppose this initiative as it will have a significant negative impact on the quality of healthcare provided to patients in Ireland. Irish physiotherapists from accredited Irish training programs are trained to a significantly higher standard than most others and therefore have a significantly broader scope of practice with much greater potential for independent practice as well as practice within part of a…
As Head of Discipline of Physiotherapy at University College Dublin, Ireland, I wish to express my concerns regarding the proposed Common Training Framework (CTF) for Physiotherapists and its potential implications for professional standards, regulatory oversight and patient safety. I strongly support professional mobility across Europe. However, mobility should not come at the expense of public protection.
I support efforts to improve professional mobility for physiotherapists and other healthcare professionals across Europe. However, I strongly oppose the proposed Common Training Framework (CTF) for Physiotherapists in its current form because it does not provide sufficient assurance regarding educational equivalence, professional competence, or patient safety.
As a member of ISCP and CORU registered Physio in Ireland I support the CTF in its current form as long as it does provide sufficient assurance that physiotherapists recognised through the framework will have attained equivalent competencies for safe and effective practice across all areas of the profession.
I am a Consultant in Sports & Exercise Medicine in Ireland and wish to express concerns regarding the proposed Common Training Framework (CTF). While I support professional mobility, the current proposal relies on minimum standards that do not reflect the level of competence and autonomy required for physiotherapy practice in Ireland.
The Spanish Association of Physiotherapists (AEF) welcomes the opportunity to comment on the draft Commission Delegated Directive establishing a Common Training Framework (CTF) for physiotherapists. We appreciate the extensive consultation process and support several key elements of the proposal.
I do not agree with the CTF. In recent years we are experiencing a very low standard of pre-qualification clinical practice/experience from students who have qualified outside of Ireland. Predominantly the experience is lacking in acute cardioresp and acute neuro. This initiative is putting out healthcare system and its users at enormous risk. This cannot be implemented
To Whom it May concern. As a Masters level Irish trained Chartered Physiotherapist and Board member of Irish Society of Chartered Physiotherapists I wish to express my grave concerns about the possibility of a common training framework.
Whilst I support freedom of movement within the EU and as a clinic owner, would struggle to find Physiotherapists to join our team and so often interview Physiotherapist entering Ireland from abroad. It has become very evident to me the difference in Physiotherapy Undergrad curriculum and exposure to hands on experience amongst newly qualified Physiotherapists from different EU countries.
The Italian Association of Physiotherapy (AIFI) supports the objectives of the Common Training Framework (CTF), which aim to promote professional mobility and the introduction of automatic recognition of qualifications among member states.
We are commenting, as authorised by the Finnish Universities Network for Rehabilitation (FiRe), on the draft common training framework for physiotherapists. We support common training framework and the facilitation of mobility. We also support EQF level 6 as the minimum level of education. However, further attention should still be paid to the content.
The proposal for a common framework is interesting, especially as it would foster mobility between nations. Moving to other countries takes a lot of time and preparation, often bureaucratic rather than technical and professional. Concerns about standards are significant. Establishing a competent body to act as a bridge between countries could ensure both issues, high training standards and shorter mobility times.
Filed in Italian · English published by the European Commission
An analysis of « the Commission Delegated Act establishing a CTF for the profession of physiotherapist » versus the « Vision of the Federal Council for Physiotherapy of Belgium » clearly illustrates that the proposed CTF is unacceptable for Belgium.
The Dutch Federation for Physiotherapy Education (SROF), representing physiotherapy education programmes in the Netherlands, has followed the development of the Common Training Framework (CTF) from the perspective of education quality, assessment and alignment with professional practice.
The Royal Dutch Society for Physical Therapy (KNGF), the professional association for physiotherapists in the Netherlands, has closely followed the development of a potential European Common Training Framework (CTF) in dialogue with national stakeholders and the professional field.
The German Social Insurance Agency (DSV) warmly welcomes the European Commission’s initiative to develop a common European training framework for the profession of physiotherapist. A harmonised training framework can make a significant contribution to simplifying recognition procedures, promoting the mobility of professionals and strengthening the quality of physiotherapeutic care across Europe.
Filed in German · English published by the European Commission
Input to the European Commissions Call for Evidence Common Training Framework (CTF) for Physiotherapists The Norwegian Physiotherapist Association (NPA) is Norways largest professional organisation for physiotherapists. We have followed the process concerning a possible European Common Training Framework (CTF) in dialogue with national authorities and the wider sector.
Comments from Physio Austria on the European Commission’s initiative for a common training framework in physiotherapy Physio Austria, Austria’s federation of physiotherapists, recognises the European Commission’s initiative to establish a common training framework for physiotherapists as an important step towards promoting professional mobility within the European Union.
Filed in German · English published by the European Commission
The Fédération Nationale des Étudiant·e·s en Kinésithérapie (FNEK) is the only organisation representing the more than 12,800 physiotherapy students in France. Its mission is to represent and defend their interests whilst actively contributing to discussions on the development of the training programme and the profession. For over 20 years, the FNEK has been involved in the transformation of physiotherapy training.
Since 2022, the National Council of the Order of Masters and Physiotherapists (CNOMK) has worked on formulating a proposal for a common high-level European training framework by leading several working parties on the subject, bringing together organisations representing the profession in many Member States of the European Union.
Filed in French · English published by the European Commission
The CTF initiative on physiotherapy is very welcome. In Austrian practice, the recognition of EU qualifications in physiotherapy often results in full equivalence of qualifications without having to attend the compensatory measures. This is also because, in addition to the bachelor’s degree, the applicants also bring a master’s degree in physiotherapy and have been employed in this field for years.
Filed in German · English published by the European Commission
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