Fair labour mobility package: Skills portability 1: digitalised cross-border portability of qualifications and skills

When it comes to higher education qualifications, it would be important to have the following points in mind: 1. Potential synergies and overlaps with the Lisbon Recognition Convention. 2. Underlying importance of quality assurance (QA) for recognition of skills and qualifications across borders.

The Association of European Border Regions (AEBR) counts some 100 members from the European Union and its neighbouring countries representing (cross-) border regions. AEBR supports fully the Commissions analysis of the need to make the best use of all skills. AEBR shares Enrico Lettas analysis in his 2024 report that the free movement of people remains the least developed of the EUs four freedoms.

We welcome the objective of enhancing transparency of skills and qualifications to facilitate cross-border labour mobility, as well as efforts to improve recognition processes for regulated professions. However, transparency alone will not remove the structural obstacles that continue to hinder labour mobility in border regions. Simplification, interoperability and faster procedures are equally necessary.

Osteopathy Europe (OE) welcomes the initiative to improve free movement of workers by enhancing transparency of skills and qualifications and to promote interoperable digital credentials across the European Union. OE is a European umbrella organisation (NGO) representing 23 national osteopathic professional associations across Europe.

The Organising Bureau of European School Student Unions (OBESSU) expresses its appreciation for the European Commission's invitation for evidence concerning the forthcoming Skills Portability Initiative (SPI). This initiative constitutes a component of the Union of Skills strategy, designed to facilitate the seamless transferability of qualifications and skills throughout the European Union.

The Organising Bureau of European School Student Unions (OBESSU) expresses its appreciation for the European Commission's invitation for evidence concerning the forthcoming Skills Portability Initiative (SPI). This initiative constitutes a component of the Union of Skills strategy, designed to facilitate the seamless transferability of qualifications and skills throughout the European Union.

The Organising Bureau of European School Student Unions (OBESSU) expresses its appreciation for the European Commission's invitation for evidence concerning the forthcoming Skills Portability Initiative (SPI). This initiative constitutes a component of the Union of Skills strategy, designed to facilitate the seamless transferability of qualifications and skills throughout the European Union.

EAEA suggests core measures to undertake that would enable the main SPI system and roadmaps for their implementation: 1) Skills validation and recognition Implementation and alignment of skills and competences validation and recognition is a fundamental step for the long-term impact of Skills Portability.

EAEA suggests core measures to undertake that would enable the main SPI system and roadmaps for their implementation: 1) Skills validation and recognition Implementation and alignment of skills and competences validation and recognition is a fundamental step for the long-term impact of Skills Portability.

GIFEN and its partner, the French University of Nuclear Skills (UMN), welcome the consultation launched by DG Employment and Social Affairs on enhancing transparency of skills and promoting interoperable digital credentials. These initiatives are key to facilitating worker mobility, strengthening the Single Market and improving the recognition of skills across the EU.

OVUNOKI (1) position on the Project Report of the European Commission (Directorate-General for Employment, Social Affairs and Inclusion) of 13 June 2025: "Feasibility of Establishing a Common Training Framework for the Profession of Physiotherapist" (1)Overarching body of the university education in Rehabilitation Sciences and Physiotherapy in Belgium Flemish Community of Belgium Key message OVUNOKI supports the…

We welcome the Commission’s recommendation on the transferability of skills, which aims to make the use of qualifications in the EU more transparent and understandable, modernise the processes for recognising regulated professions and simplify these procedures for third-country nationals, with the aim of enhancing labour mobility, reducing administrative burdens and enhancing investment in skills.

Filed in Italian · English published by the European Commission

The National Council of the Order of Social Assistants welcomes with interest the Commission’s initiative to modernise and make more effective the processes for the recognition of professional qualifications. The experience gained over the years in the examination of applications for recognition of qualifications obtained abroad shows that there is real room for improvement, in particular in terms of documentary…

Filed in Italian · English published by the European Commission

Consejo COLEF (Consejo General de Colegios Oficiales de Licenciados en Educación Física y en Ciencias de la Actividad Física y del Deporte), Spanish public-law professional body representing university graduates in Sport Sciences and Physical Education, welcomes the European Commissions initiative under Skills Portability Action 3 aimed at simplifying the recognition of qualifications and skills of third-country…

Consejo COLEF (Consejo General de Colegios Oficiales de Licenciados en Educación Física y en Ciencias de la Actividad Física y del Deporte), Spanish public-law professional body representing university graduates in Sport Sciences and Physical Education, welcomes the Skills Portability Initiative Action 1 and its objective of strengthening worker mobility through enhanced skills transparency and digitalisation.

1. The core problem: qualification recognition is disconnected from labour migration Greece's metaklisi procedure under the Migration Code (N. 5038/2023, as amended by N. 5275/2026 transposing Directive 2024/1233) allows employers to recruit third-country nationals by specifying a specialty and obtaining a work permit. However, no mechanism verifies whether the worker holds matching qualifications.

Consejo COLEF (Consejo General de Colegios Oficiales de Licenciados en Educación Física y en Ciencias de la Actividad Física y del Deporte), Spanish public-law professional body representing university graduates in Sport Sciences and Physical Education, welcomes the European Commissions initiative under Skills Portability Action 2 aimed at facilitating, modernising and expanding recognition processes for regulated…

The European Federation for Family Employment and Home Care (EFFE) welcomes the European Commissions Skills Portability Initiative as a timely response to labour shortages, demographic change, and structural barriers to worker mobility across the EU.

Si accoglie con favore l’iniziativa della Commissione sulla trasferibilità delle competenze, che mira a rendere più trasparente e comprensibile l’uso delle qualifiche nell’Unione, a modernizzare i processi di riconoscimento delle professioni regolamentate e a semplificare le procedure in parola per i cittadini di Paesi terzi, con l’obiettivo di rafforzare la mobilità dei lavoratori, ridurre gli oneri amministrativi…

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Si accoglie con favore l’iniziativa della Commissione sulla trasferibilità delle competenze, che mira a rendere più trasparente e comprensibile l’uso delle qualifiche nell’Unione, a modernizzare i processi di riconoscimento delle professioni regolamentate e a semplificare le procedure in parola per i cittadini di Paesi terzi, con l’obiettivo di rafforzare la mobilità dei lavoratori, ridurre gli oneri amministrativi…

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Students Union (ESU) represents 40 national student unions across 43 countries. For ESU, the upcoming Skills Portability Initiative (SPI) must build on rather than duplicate existing European frameworks for recognition and mobility.

The European Council of the Liberal Professions (CEPLIS), registered in the European Union Transparency Register under number 638812928460-69, with its office in Rue Saint-Georges 32, Brussels, hereby submits its contribution to the Skills Portability Initiative. Contact email: [email removed].

Project Management Institute (PMI) is a not-for-profit organisation and a leading global authority in project management, advancing the profession through globally recognised standards, frameworks, certifications and continuous learning used across borders by employers and professionals.

Project Management Institute (PMI) is a not-for-profit organisation and a leading global authority in project management, advancing the profession through globally recognised standards, frameworks, certifications and continuous learning used across borders by employers and professionals.

Response to the European Commission’s Call for Evidence for an Impact Assessment on the Skills Portability Initiative Introduction LinkedIn connects the world’s professionals to make them more productive and successful and transforms how companies hire, learn, market, and sell.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Project Management Institute (PMI) is a not-for-profit organisation and a leading global authority in project management, advancing the profession through globally recognised standards, frameworks, certifications and continuous learning used across borders by employers and professionals.

The document "Artificial Intelligence supporting the Skills Portability Initiative" outlines a strategic framework for using AI to create an interoperable, inclusive, and trustworthy European labor market. Below is a detailed summary of its key pillars. 1. AI as a Universal Translator for Skills The primary barrier to labor mobility is the fragmentation of qualifications.

EFHOH welcomes the European Commissions initiative to strengthen the portability of skills and qualifications across the EU. Facilitating labour mobility, improving recognition procedures, and modernising digital systems are essential to strengthen the Single Market and address labour shortages. For hard of hearing people, however, portability of qualifications is not only an administrative matter.

Feedback from EuropeOn, the European Association of Electrical Contractors: >As a principle, recognitions of qualifications should benefit from streamlined, transparent and time-bound administrative procedures, trustworthy digital tools, and clear document lists and contact points in the relevant administrations >Encouraging mobility from third countries to fill gaps in Europe is worth exploring and there may be an…

Feedback from EuropeOn, the European Association of Electrical Contractors: >As a principle, recognitions of qualifications should benefit from streamlined, transparent and time-bound administrative procedures, trustworthy digital tools, and clear document lists and contact points in the relevant administrations.

Feedback from EuropeOn, the European Association of Electrical Contractors: >EU instruments such as EQFs, the Europass, or ESCO can be useful as voluntary and supportive add-ons but should not become mandatory in any way that would give them primacy over effective national frameworks >Relevant authorities should involve social partners in any initiatives impacting the qualifications of professionals to foster the…

TheCityUK is the industry led body representing financial and related professional services firms with a presence in the UK, including many firms that are headquartered in the EU and operate across multiple jurisdictions.

Please find enclosed the Statement: Skills Portability Initiative: Enabling Mobility While Safeguarding Quality and Trust by the Renewable Energy Skills Partnership. The Skills Portability Initiative should focus on: Transparency and comparability Trustworthy validation Social partner governance Practical mobility pathways Support for SMEs ------------------------ About the Renewable Energy Skills Partnership The…

In line with the Council of European Dentists (CED)s position on the Recognition of Dental Professional Qualifications acquired in Third Countries, as well as the 2023 Commission Recommendation on the recognition of qualifications of third-country nationals, the CED underscores the importance of improving existing EU automatic recognition of basic dental qualifications listed under Annex V.3.2 of Directive…

Promoting the mobility of workers is a very important objective. The Confederation of Finnish Industries (EK) supports measures to facilitate the identification of skills. According to the EK Key, Finnish companies do not consider the identification of skills acquired elsewhere to be a major challenge. The survey was carried out in May 2025 by a sample survey of 613 EK member companies.

Filed in Finnish · English published by the European Commission

The free movement of people, knowledge, and expertise is a cornerstone of an effective and attractive European Research Area (ERA). A significant barrier to this mobility is the limited portability of qualifications and skills across the EU.

The Council of European Dentists (CED), representing over 340 000 dentists across Europe, acknowledges the importance of strengthening the transparency and accountability of skills, whether acquired throughout undergraduate dental training, including clinical or theoretical skills, postgraduate training or continuing professional development (CPD).

Please find attached: An initial list of governmental skills mobility partnerships (SMPs) from ICMPDs Link4Skills mapping. The list includes information on SMP design with regard to skills and qualifications recognition, where information is available (fewer than 1/3 of initiatives mapped). Further details available (https://corridors.link4skills.eu/partnerships).

European DIGITAL SME Alliance, representing over 45,000 tech SMEs from across Europe, supports the objectives of the Skills Portability Initiative as a timely effort to strengthen the mobility of skills across the European Union, at a moment when labour shortages and accelerating digital transformation are placing increasing pressure on the Single Market.

The ACE represents over 500,000 architects from 36 European countries (including all EU Member States) through 53 Member Organisations, plus observers and special status members (e.g., UK, Switzerland, Norway). ACE welcomes the skills portability initiative to boost the internal market and EU competitiveness.

Propositions pour la future initiative de la Commission Européenne « Portabilité des compétences dans l’UE » Février 2026 Le MEDEF soutient la libre circulation des travailleurs et la portabilité des compétences. Le MEDEF a d’ailleurs formulé en 2024 des propositions pour soutenir la mobilité des ressortissants européens pour faire face aux pénuries de main d’œuvre en Europe.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Objection BY THE FEDERAL COUNCIL FOR THE kinesitherapy OF BELGIUM TEGEN DE PLANNEN M.B.T. THE INSTELLATION OF A COMMON TRAINING FRAMEWORK FOR kinesitherapy Cfr. the attached documents Objection TO THE PLANS regarding THE ESTABLISHMENT OF A COMMON TRAINING FRAMEWORK FOR Physiotherapy See the attached files Objection DU CONSEIL FEDERAL DE LA KINESITHEREAPIE DE LA BELGIQUE AUX PLANS concernant LA MISE EN PLACE D’UN…

Filed in Dutch · English published by the European Commission

From a further and higher education perspective, Malta fully supports facilitating mobility and removing remaining obstacles in recognition processes and has already delivered significant legislative, administrative and digital reforms at national level. Malta has actively contributed to updates of minimum training requirements for sectoral professions and invested heavily in digital solutions.

From a further and higher education perspective, Malta remains cautious about EU-level rules on recognition of TCN qualifications and already asked the Commission to take into consideration mechanisms to prevent serious risks related to fraud, verification, and lack of cooperation from third-country authorities.

From a further and higher education perspective, Malta supports transparency and digitalisation, including the use of European Digital Credentials, where these support existing national systems. Malta stresses the need to preserve national competences and policy flexibility, particularly in recognition processes and the use of digital tools and cautions against EU-level solutions that could impose financial…

The limited portability of skills and qualifications obtained outside the EU remains a significant barrier to labour mobility, constraining Single Market efficiency, competitiveness, talent attraction, retention and inclusion.

FIEC, the European Construction Industry Federation, welcomes the Skills Portability Initiative which will be presented in the framework of the Fair Labour Mobility Package in the second half of 2026. Please, find attached FIEC's answer to the call for evidence.

Reactie NRTO op de EU-internetconsultatie Initiatief voor de overdraagbaarheid van vaardigheden Samenvatting De Nederlandse Raad voor Training en Opleiding (NRTO), branchevereniging voor private opleiders, verwelkomt het initiatief van de Europese Commissie om de overdraagbaarheid van vaardigheden binnen de Europese Unie te versterken.

Filed in Dutch · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DHL Contribution to the Call for Evidence – Skills Portability Initiative DHL Group strongly supports the objectives of the EU Skills Portability Initiative, particularly its ambition to improve mobility of skills and qualifications across Member States. Predictability remains one of the main challenges by skill acknowledgment. Processes must be accelerated and transparency for all participants must be increased.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Union of Local Enterprises (U2P) represents 3.4 million micro, small and medium-sized enterprises in the craft, local trade and liberal professions sectors, i.e. 2/3 of French enterprises. It is the first organisation to represent the self-employed.

Filed in French · English published by the European Commission

Tehy is the largest trade union in Finland for professionals and students in social services, health care, and early childhood education. Tehy emphasises that in the EU, improving nurses' working conditions and wages must be a priority to ensure successful recruitment and retention.

Today, having your skills and qualifications understood by employers in other EU Member States remains challenging, also because diplomas are often paper-based. This initiative aims to build on existing tools for transparency of skills and qualifications and to explore the promotion of interoperable digital credentials.

Filed in Italian · English published by the European Commission

The European Association of Hospital Pharmacists (EAHP) welcomes the Commissions initiative to adopt a comprehensive approach aimed at facilitating the mobility of workers. EAHP represents over 30,000 hospital pharmacists across 37 member countries.

ETSA, the European Textile Service Association, represents and works on behalf of the textile services industry, which provides laundering and rental services for reusable textile products such as workwear, linen and uniforms, and represents textile manufacturers, national associations, machinery suppliers and detergent producers across the EU.

The European Transport Workers Federation ETF is the pan-European organization representing over 5 million transport workers, operating on land, sea or air. ETF's points are better detailed in the document attached. ETF, in principle, stands behind the objective of the Skills Portability Initiative.

First, it is important to create a level playing field: learners at VET level are entitled to equal access, resources and opportunities to study, live and work abroad. This requires consistent and transparent communication in accessible language and equal access to systems, regardless of educational level. The ability to easily search for and find information about studying or working abroad is a basic precondition.

The full contribution of the Syndicat Français Des Osteopathes (SFDO) is attached. SFDO fully supports the European objective of facilitating occupational mobility. However, in the field of health, mobility cannot be dissociated from a high and harmonised requirement for training and skills.

Filed in French · English published by the European Commission

français  Ref. Ares(2026)2209184 - 27/02/2026 (https://ec.europa.eu) European Commission (https://ec.europa.eu/index_en.htm)  EUSurvey Questionnaire de consultation publique à l’appui de l’initiative sur la transférabilité des compétences - Action nº 3: une éventuelle proposition législative relative à des règles communes visant à simplifier les procédures de reconnaissance des qualifications et des compétences…

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As a public employment and training service, we welcome all initiatives to facilitate labour mobility and foster national and international recognition of formal and non-formal skills. Modernising and adapting the system of recognition of diplomas, qualifications and qualifications of regulated professions is a priority.

Filed in French · English published by the European Commission

The Centre for Cross Border Cooperation's full feedback is provided in the attached file. In summary, we note that the exact type of initiatives is still to be determined but we welcome the indicative actions outlined which aim to meet the objectives of: Facilitating worker mobility through improved transparency of skills and qualifications and digitalisation.

Na onales Europass Center Deutschland in der Na onalen Agentur beim Bundesins tut für Berufsbildung www.europass-info.de Ref. Ares(2026)2206741 - 27/02/2026 27.02.2026 Öffentliche Konsulta on zur Anerkennung von Qualifika onen und Kompetenzen Stellungnahme des Na onalen Europass Centers in der NA beim BIBB zur Maßnahme 1 - möglicher Legisla vvorschlag zur Erleichterung der Mobilität von Arbeitnehmern durch verbesserte…

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

1. Psychology as a diversely regulated profession Psychology is a scientific profession that is regulated in many EU Member States, often partly or fully under health legislation. Regulation, scope of practice and required training differ significantly across countries. Regulation may be justified by reasons of public interest, including patient safety.

LUNSA, together with ETUC, called for an initiative on skills portability that strengthens workers’ rights, ensures fair mobility and prevents wage and social dumping. The initiative must improve employability and job quality, while avoiding approaches that prioritise talent search and labour supply over decent work.

Filed in French · English published by the European Commission

LUNSA, together with ETUC, called for an initiative on skills portability that strengthens workers’ rights, ensures fair mobility and prevents wage and social dumping. The initiative must improve employability and job quality, while avoiding approaches that prioritise talent search and labour supply over decent work.

Filed in French · English published by the European Commission

LUNSA, de concert avec la CES, appelle à une initiative sur la portabilité des compétences qui renforce les droits des travailleurs, garantisse une mobilité équitable et prévienne le dumping salarial et social. Linitiative doit améliorer lemployabilité et la qualité de lemploi, tout en évitant des approches qui privilégient la recherche de talents et loffre de main-dœuvre au détriment du travail décent.

Agorà Italian Academy operates as a cross-border VET ecosystem between Italy and Slovakia, structured around a governance-based competence architecture aligned with EQF transparency principles and progressively compatible with national qualification frameworks. Between 2023 and 2026, the Academy has trained over 2,650 students, with 450 annual structured internships and a 75% employment rate within 12 months.

The recognition of qualifications and skills of third-country nationals (TCNs) remains a major bottleneck for European employers. Based on Fragomens extensive practical experience supporting employers and individuals across Member States, key recurring challenges include: Lack of coordination between recognition and immigration systems.

BKZT summary: Important aspects to consider for planning and design services The BKZT contribution focuses on architectural and chartered engineering planning services, which must be clearly distinguished from construction works. Planning services are intellectual, knowledge-based services shaping the (built) environment throughout its lifecycle, independent of specific products and producers.

BKZT summary: Important aspects to consider for planning and design services The BKZT contribution focuses on architectural and chartered engineering planning services, which must be clearly distinguished from construction works. Planning services are intellectual, knowledge-based services shaping the (built) environment throughout its lifecycle, independent of specific products and producers.

European Hospital and Healthcare Employers’ Association Brussels, 27 February 2026 oh/lm Skills Portability Initiative Following the dedicated social partners’ hearing of 23 January 2026, this note presents HOSPEEM view on the European Commission’s proposed skills portability initiative.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

European Hospital and Healthcare Employers’ Association Brussels, 27 February 2026 oh/lm Skills Portability Initiative Following the dedicated social partners’ hearing of 23 January 2026, this note presents HOSPEEM view on the European Commission’s proposed skills portability initiative.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

European Hospital and Healthcare Employers’ Association Brussels, 27 February 2026 oh/lm Skills Portability Initiative Following the dedicated social partners’ hearing of 23 January 2026, this note presents HOSPEEM view on the European Commission’s proposed skills portability initiative.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ZDH Basically supporting measures to promote the free movement of workers. The EU should support the recognition of qualifications but not impose additional legal regulations. The requirements for professional qualifications set by the destination countries must continue to be decisive. The recognition of foreign professional qualifications acquired in EU countries play a subordinate role in Germany.

Filed in German · English published by the European Commission

ZDH Basically supporting measures to promote the free movement of workers. The EU should support the recognition of qualifications but not impose additional legal regulations. The requirements for professional qualifications set by the destination countries must continue to be decisive. The recognition of foreign professional qualifications acquired in EU countries play a subordinate role in Germany.

Filed in German · English published by the European Commission

ACTION 3 : 4 remarks are made by FEDCAR. FEDCAR is the federation of European regulators and competent authors for the recognition of dental qualifications. 3.1 The implementation of EU Recommendation 2023/2611 of 15 November 2023 on the recognition of qualifications of third-country nationals is encouraged, instead of adopting a new legislative initiative.

FEDCAR is the federation of European regulators and competent authors for the recognition of dental qualifications. ACTION 1 - FEDCAR has 2 remarks. On micro-credentials : any initiative that can contribute to the comparability and recognition of micro-credentials, and by doing so, can facilitate the duties of a Continued Professional Development organized in each country is welcome.

Then German Confederation of Skilled Craftsa and Small Businesses (ZDH) Basically supports measures to promote the free movement of workers. The EU should support the recognition of qualifications but not impose additional legal regulations. The requirements for professional qualifications set by the destination countries must continue to be decisive.

Filed in German · English published by the European Commission

Please find attached CPMEs position paper in response to the European Commissions reflections on the portability of skills and qualifications. As Frances leading employers organisation in terms of number of enterprises represented, CPME welcomes the opportunity to contribute to this important initiative.

Action No 3: The National Order of Dentists (Ordre National des Chirurgiens-Dentistes – ONCD) recognises dental qualifications in France, where more than 50 % of first-time registrants each year have an EU diploma. LONCD is of the opinion that the measures already planned should be implemented and that the specific nature of the health professions should be borne in mind.

Filed in French · English published by the European Commission

The National Order of Dentists (Ordre National des Chirurgiens-Dentistes – ONCD) recognises dental qualifications in France, where more than 50 % of first-time registrants each year have an EU diploma. LONCD is also responsible by the State for regulating and honouring the profession, protecting patients and organising the continuity of care.

Filed in French · English published by the European Commission

More talent in the EU through less bureaucracy and more digitalisation This document has been machine-translated from German. The original German version is available here. Position paper on the planned EU Skills Portability Initiative 26 February 2026 Summary Europe needs skilled workers.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

More talent in the EU through less bureaucracy and more digitalisation This document has been machine-translated from German. The original German version is available here. Position paper on the planned EU Skills Portability Initiative 26 February 2026 Summary Europe needs skilled workers.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

More talent in the EU through less bureaucracy and more digitalisation This document has been machine-translated from German. The original German version is available here. Position paper on the planned EU Skills Portability Initiative 26 February 2026 Summary Europe needs skilled workers.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Putting SMEs at the heart of the important initiative on skills portability can truly strengthen the single labour market and contribute to more inclusive and sustainable economic development for the whole EU, which means: assess quickly and confidently a candidate trained in another Member State or in a third country, reduce uncertainty related to foreign qualifications and contain indirect costs resulting from…

Filed in Italian · English published by the European Commission

Slovenian Chamber of Engineers (IZS) Feedback Call for Evidence – Skills Portability Initiative 1. Broad Representation The Slovenian Chamber of Engineers (Inženirska Zbornica Slovenije, IZS) is a modern, respected, and trustworthy institution with more than 6,800 authorized and supervisory engineers of various professions, involved in design and construction of buildings and infrastructure.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CEI-Bois supports the Commissions ambition to improve labour mobility and strengthen the EUs competitiveness. At the same time, we wish to emphasise that simplification, harmonisation and improved implementation of existing systems should be the main focus.

Principios comunes de formación y tarjeta profesional europea para ingenieros El desarrollo de la propuesta de la Directiva 2005/36/CE en los aspectos concernientes a la tarjeta profesional europea para ingenieros, y su extensión a otras profesiones, así como la implementación de los principios comunes de formación, es una gran oportunidad para Europa, ya que permitirá avanzar hacia una mayor convergencia…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Principios comunes de formación y tarjeta profesional europea para ingenieros El desarrollo de la propuesta de la Directiva 2005/36/CE en los aspectos concernientes a la tarjeta profesional europea para ingenieros, y su extensión a otras profesiones, así como la implementación de los principios comunes de formación, es una gran oportunidad para Europa, ya que permitirá avanzar hacia una mayor convergencia…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Principios comunes de formación y tarjeta profesional europea para ingenieros El desarrollo de la propuesta de la Directiva 2005/36/CE en los aspectos concernientes a la tarjeta profesional europea para ingenieros, y su extensión a otras profesiones, así como la implementación de los principios comunes de formación, es una gran oportunidad para Europa, ya que permitirá avanzar hacia una mayor convergencia…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CAS/BR10379/SMR Brussels, 26 February 2026 IRU CONTRIBUTION TO THE CALLS FOR EVIDENCE AND CONSULTATIONS ON THE FAIR LABOUR MOBILITY PACKAGE Click here to enter comments IRU contribution to the open calls for evidence and consultations on the Fair Labour Mobility Package initiatives I.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CAS/BR10379/SMR Brussels, 26 February 2026 IRU CONTRIBUTION TO THE CALLS FOR EVIDENCE AND CONSULTATIONS ON THE FAIR LABOUR MOBILITY PACKAGE Click here to enter comments IRU contribution to the open calls for evidence and consultations on the Fair Labour Mobility Package initiatives I.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CAS/BR10379/SMR Brussels, 26 February 2026 IRU CONTRIBUTION TO THE CALLS FOR EVIDENCE AND CONSULTATIONS ON THE FAIR LABOUR MOBILITY PACKAGE Click here to enter comments IRU contribution to the open calls for evidence and consultations on the Fair Labour Mobility Package initiatives I.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EFAA for SMEs – Comments on the EU Initiative: Skills portability, action 2 – facilitating, modernising and expanding recognition processes for regulated professions 27 February 2026 EFAA for SMEs is pleased to comment on the proposed Skills Portability Initiative and to confirm its support for labour mobility across Europe.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Action 3: Simplify the recognition of qualifications and competences of third-country nationals For the CGCOM, this action is particularly relevant as it would simplify the recognition of complementary training for doctors from third countries, especially in accordance with global accreditation/certification schemes.

Filed in Spanish · English published by the European Commission

Action 2: Facilitate, modernise and expand the recognition processes for regulated professions The medical profession is one of the most critical regulated professions, so any modernisation of professional recognition is of utmost interest to the CGCOM, provided that it preserves the levels of quality and safety for both doctors and patients.

Action 1: Facilitate worker mobility across the EU through transparency of skills and their digitalisation The Spanish General Medical Council (hereinafter CGCOM) has already developed verifiable credentials, such as the professional identity (DoctorID), and will continue to develop other credentials (Certificate of Good Standing (eCIP) and Good Medical Practice (BQM), etc.) that are fully in line with the objective…

Research conducted by the TourXpeRience consortium, a European Centre of Vocational Excellence (CoVE) involving 21 partners across nine EU countries, highlights significant gaps between vocational education and training (VET) provision and the actual needs of the tourism labor market.

Respuesta a la consulta pública sobre la Iniciativa UE de Portabilidad de las Competencias CONFEBUS toma nota de la apertura de consulta pública relativa a la Iniciativa de Portabilidad de las Competencias, cuyo objetivo es garantizar la portabilidad de cualificaciones y competencias en la UE y reforzar su atractivo para el talento, en particular mediante la simplificación y digitalización de los procedimientos y el…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Commissions Third Action Plan from the "Skills and Talent Mobility" package is a significant opportunity to meet labour shortages in the European Union (EU) by allowing Indian professionals to migrate globally.

As a global non-profit association focused on advancing cybersecurity skills, ISC2 welcomes the EU Commissions efforts to remove barriers to mobility while maintaining high standards of competence and trust. The initiative will support labour mobility in the EU and attract global talent.

The European Federation of Geologists (EFG) welcomes the Skills Portability Initiative launched by the European Commission and strongly endorses its aims to promote labour mobility, enhance skills transparency, and reinforce the effective functioning of the EU Single Market.

The ABDA (Federal Association of German Pharmacists’ Associations) welcomes the European Commission’s initiative to promote labour mobility across the EU through improved transparency of skills and digitalisation, but at the same time stresses the urgent need for the European Qualifications Framework (EQF) to remain a recommendation, as it guarantees greater transparency.

Filed in German · English published by the European Commission

The European Federation of Geologists (EFG) welcomes the Skills Portability Initiative launched by the European Commission and strongly endorses its aims to promote labour mobility, enhance skills transparency, and reinforce the effective functioning of the EU Single Market.

With regard to the use of electronic and digital procedures for the exchange and recognition of evidence of qualifications and competences, we would point out that this should not lower existing standards. Existing or currently emerging procedures in the Member States should be taken into account and not compromised (e.g.

Filed in German · English published by the European Commission

The European Federation of Geologists (EFG) welcomes the Skills Portability Initiative launched by the European Commission and strongly endorses its aims to promote labour mobility, enhance skills transparency, and reinforce the effective functioning of the EU Single Market.

The Erasmus Student Network contributes to this consultation from the perspective of Europes mobile learners. Founded in 1989 to support the implementation of the Erasmus programme, ESN has evolved into the largest European student and alumni organisation dedicated to credit and degree mobility.

EUFASA aisbl is the umbrella association of 22 national member associations representing foreign service families. Diplomatic spouses and partners accompany EU civil servants and diplomats across Europe and around the world, moving on average every three years throughout their working lives.

In addition to ETUC views on Skills Portability Initiative, the DGB explains its position on the proposal for a Skills Portability Initiative. The German Trade Union Confederation (DGB) emphasizes the importance of recognizing foreign qualifications as a means to combat exploitation, improve working conditions, and facilitate access to training.

Welcomes the European Commission’s objectives of speeding up procedures, improving professional mobility and advancing digitalisation and transparency, insofar as they can contribute to a better functioning of the internal market. Representing the more than 53.000 registered professionals, it is reported that the profession of Social Work is a qualified, regulated and registered profession.

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The cities of Helsinki, Espoo, Tampere, Vantaa, Oulu and Turku would like to thank for the possibility to comment on the Skills Portability Initiative. The cities are important providers of education and employment services, and therefore we welcome EU-wide measures to increase the transparency and comparability of qualifications and skills, to modernise recognition procedures for EU citizens access to regulated…

The Dutch Institute of Psychologists (NIP), the largest professional association of psychologists in the Netherlands, endorses the importance of international mobility of professionals, also because of the current shortages of postgraduate trained psychologists and their specific expertise in Europe.

ENSIE, the European Network of Work Integration Social Enterprises, is the leading European representative body for national and regional networks of Work Integration Social Enterprises (WISEs). It advocates for more inclusive labour markets by promoting enterprises whose core mission is the social and professional integration of disadvantaged people through economic activity combined with strong pedagogical…

Rückmeldung zur Sondierung und öffentlichen Konsultation zur Skills Portability Initiative Wien, 26.02.2025 Über den Verband der öffentlichen Wirtschaft und Gemeinwirtschaft Österreichs Unser Ziel ist es, dass Dienstleistungen der Daseinsvorsorge für alle Menschen in Österreich zugänglich, leistbar und von hoher Qualität bleiben – heute und in Zukunft.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

1. It is appropriate to provide for the publication of previous recognitions of certain certificates or training courses. Article IX.2 Lisbon Recognition Convention and Article 4 of Regulation 2018/1724 provide a legal basis for the mandatory publication of precedents: the fact that certain diplomas of certain institutions have already been recognised is one of their own information, which must be shared with…

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The French Federation of Psychologists and Psychology wished to respond to this consultation on 6 points: - Psychology as a diversely regulated profession - Qualifications and Skills - Recognition for Access to Regulated Professions - Mental Health Workforce Shortages and Mobility - Third-Country Qualifications This concerns only the mobility of psychologists.

C/ Nicasio Gallego 8 28010 Madrid https://economistas.es/ La mejora de los mecanismos de reconocimiento entre los diversos países puede acelerar significativamente la expansión empresarial. Si se establecen procesos de reconocimiento más ágiles y rápidos, se pueden reducir significativamente las barreras administrativas, se simplifica los trámites burocráticos y se facilita la entrada a proyectos transfronterizos…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Federation of Cleaning Industries (EFCI) recommends that consideration be given to the introduction of a European Cleaning Skills Card - a formal, industry-wide initiative aimed at raising standards and ensuring consistency in training across the cleaning sector.

C/ Nicasio Gallego 8 28010 Madrid https://economistas.es/ La mejora de los mecanismos de reconocimiento entre los diversos países puede acelerar significativamente la expansión empresarial. Si se establecen procesos de reconocimiento más ágiles y rápidos, se pueden reducir significativamente las barreras administrativas, se simplifica los trámites burocráticos y se facilita la entrada a proyectos transfronterizos…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Speaking from the piont of view of professionals working in the cultural and creative sector, the upskilling via various formats of practise-based learning and even coopration skills or innovation management skills should be portable via some forms microskills recognition validated by a trainer/mentor or relevant short program.

Brüssel, 25. Februar 2026 Deutsche Industrie- und Handelskammer Rückmeldung Skills Portability Konsultation A. Das Wichtigste in Kürze Die Förderung der innereuropäischen Arbeitskräftemobilität sowie die Zuwanderung von qualifizierten Arbeitskräften aus Drittstaaten sind Maßnahmen zur Bekämpfung des immer noch grassierenden Fachkräftemangels in Deutschland.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Despite existing EU tools, skills and qualifications are still too often unclear or mistrusted across borders. Fragmented recognition procedures, sectoral differences and legal and administrative barriers hinder mobility and recruitment. This is particularly visible in vocational and regulated professions, but affects graduates, researchers and third-country nationals (TCNs) across all education sectors.

ÖFFENTLICHE KONSULTATION ZUR SKILLS PORTABILITY INITIATIVE RÜCKMELDUNG DER WIRTSCHAFTSKAMMER ÖSTERREICH / AUSTRIAN FEDERAL ECONOMIC CHAMBER Februar 2026 MAßNAHME 1 Portabilität von Kompetenzen, Maßnahme 1 – Förderung der Arbeitskräftemobilität in der gesamten EU durch verbesserte Transparenz bei Kompetenzen und durch Digitalisierung Die grenzüberschreitende Übertragbarkeit von Berufsbildungsabschlüssen bleibt eine…

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

A non-paper of Cities of Helsinki, Espoo, Tampere, Vantaa, Oulu and Turku on the Skills Portability Initiative The cities of Helsinki, Espoo, Tampere, Vantaa, Oulu and Turku would like to thank for the possibility to comment on the Skills Portability Initiative.

EUConsult, founded in Amsterdam in 1991, is an association and community of European consultants specialising in support for non-profit and civil society organisations. As a Correspondent organisation of CEPLIS, EUConsult strongly supports the European Skills Portability initiative and underlines its value.

Despite existing EU tools, skills and qualifications are still too often unclear or mistrusted across borders. Fragmented recognition procedures, sectoral differences and legal and administrative barriers hinder mobility and recruitment. This is particularly visible in vocational and regulated professions, but affects graduates, researchers and third-country nationals (TCNs) across all education sectors.

Despite existing EU tools, skills and qualifications are still too often unclear or mistrusted across borders. Fragmented recognition procedures, sectoral differences and legal and administrative barriers hinder mobility and recruitment. This is particularly visible in vocational and regulated professions, but affects graduates, researchers and third-country nationals (TCNs) across all education sectors.

For architects, automatic recognition under Directive 2005/36/EC works very well. The recognition rate of around 94 % demonstrates the functioning of the system. There is a need to address the structural clarity of training pathways, the system coherence of access conditions, and the transparency and digital operability of evidence and procedures.

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The European maritime manufacturing industry is a strategic industrial ecosystem for Europes security, energy transition, trade, blue economy, naval capabilities and decarbonisation objectives. However, the industry is facing persistent and structural labour shortages across most Member States.

Training abroad and recognition of qualifications: The Danish Trade Union Confederation recognises the potential of increased mobility but stresses that mobility must remain voluntary not mandatory. Mobility and recognition of qualifications must never lead to wage- or working-condition dumping.

The European Coordinating Committee on Veterinary Training (ECCVT) is a platform where academia (EAEVE), veterinary specialists (EBVS), veterinary students (IVSA) and the veterinary profession (FVE) exchange and coordinate their views on veterinary education.

The Consiglio Nazionale dei Periti Industriali e dei Periti Industriali Laureati (CNPI), as the representative authority of a regulated technical profession operating in the fields of energy, infrastructure, security, industrial digitalisation and ecological transition, strongly supports the Skills Portability Initiative.

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The Consiglio Nazionale dei Periti Industriali e dei Periti Industriali Laureati (CNPI), as the representative authority of a regulated technical profession operating in the fields of energy, infrastructure, security, industrial digitalisation and ecological transition, strongly supports the Skills Portability Initiative.

Filed in Italian · English published by the European Commission

The Consiglio Nazionale dei Periti Industriali e dei Periti Industriali Laureati (CNPI), as the representative authority of a regulated technical profession operating in the fields of energy, infrastructure, security, industrial digitalisation and ecological transition, strongly supports the Skills Portability Initiative.

Filed in Italian · English published by the European Commission

Key messages: DA supports the development of for a more flexible and digital recognition of qualifications to promote labour mobility across the EU and attract workers from countries outside the EU. DA fully supports initiatives that support labour mobility, strengthen the functioning of the internal market and enhance European competitiveness by making skills and qualifications more transparent, comparable and…

In general Danish Association of Vocational and Upper Secondary Schools (DEG) welcome the ambition to enhance transparency, simplification, and portability of skills and competences with the goal to strengthening the free movement and Europes overall competitiveness.

The Institut der Wirtschaftsprüfer in Deutschland e.V. (IDW) recognises the need to exploit the potential of the single market for skills and also to increase the skills of third-country nationals. Any desirable reduction in red tape must be designed in such a way as not only not to lower the quality level of professional qualifications, but to raise the level and drive a competition for excellence for the best…

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Die Wirtschaftsprüferkammer nimmt dankend die Gelegenheit wahr, zur Initiative der Kommission zur Portabilität von Kompetenzen Stellung zu nehmen: Die Wirtschaftsprüferkammer kann die Notwendigkeit gut nachvollziehen, bereits vorhandene Kompetenzen, auch von Drittstaatsangehörigen, besser zu nutzen.

The Dienst Uitvoering Onderwijs (DUO) is the executive agency of the Dutch Ministry of Education, Culture and Science. DUO is responsible for implementing national education policies and providing essential public services to students, educational institutions, and citizens.

As the umbrella organisation of the 1874 German hospitals in public, non-profit and private ownership, the German Hospital Association (DKG) has been constructively involved in health policy debates at EU level for many years. German hospitals are also keen to engage constructively in the discussion on appropriate approaches to address the challenges posed by skills shortages and portability.

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The Federal Association of Dentists – Arbeitsgemeinschaft der Deutschen Zahnärztekammern e.V. (BZÄK) represents the health and professional policy interests of the dental profession in Germany. The members of the Federal Chamber of Dentists are the seventeen chambers of dentists of the Länder of Germany.

Filed in German · English published by the European Commission

The Federal Association of Dentists – Arbeitsgemeinschaft der Deutschen Zahnärztekammern e.V. (BZÄK) represents the health and professional policy interests of the dental profession in Germany. The members of the Federal Chamber of Dentists are the seventeen chambers of dentists of the Länder of Germany.

Filed in German · English published by the European Commission

The cities of Helsinki, Espoo, Tampere, Vantaa, Oulu and Turku would like to thank for the possibility to comment on the Skills Portability Initiative. The cities are important providers of education and employment services, and therefore we welcome EU-wide measures to increase the transparency and comparability of qualifications and skills, to modernise recognition procedures for EU citizens access to regulated…

With regard to the transferability of skills and the facilitation of labour mobility in the EU through skills transparency and digitalisation, we would point out, in addition to the need for uniformity in the rules and models adopted in the various EU countries, that there are regulated and unregulated professions in the EU, including within the same sector, but, as the European Court of Auditors has already pointed…

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Make Mothers Matter believes that if the EU wants to attract, develop and retain talent, as set out in the Union of Skills, it must ensure that parents and mothers in particular are fully included in that objective. Upskilling and reskilling strategies should build on the skills that already exist within the population, enabling individuals to transfer their competences across sectors and throughout their careers.

The Institute for Transnational and Euregional Cross-border Cooperation and Mobility (ITEM, Maastricht University) was founded in 2015. One of ITEMs core tasks is carrying out Cross-Border Impact Assessments. With these assessments, ITEM strives to give insight into the effects of new legislation and policy on border regions and on how existing law and policy affect border regions.

The Lifelong Learning Platform European civil society for education (LLLP) is very active in the topic of skills since its creation 20 years ago. It has followed closely and contributed to main EU policy developments in this area, such as the Council Recommendation on the validation of non-formal and informal learning (2012), the Council Recommendation on upskilling pathways (2016), the Council Recommendation on Key…

The Lifelong Learning Platform European civil society for education (LLLP) is very active in the topic of skills since its creation 20 years ago. It has followed closely and contributed to main EU policy developments in this area, such as the Council Recommendation on the validation of non-formal and informal learning (2012), the Council Recommendation on upskilling pathways (2016), the Council Recommendation on Key…

TÜV AUSTRIA Hellas welcomes the European Commissions initiative to strengthen skills portability and enhance mutual trust in qualifications across the European Union. As an accredited personnel certification body operating in accordance with ISO/IEC 17024, TÜV AUSTRIA Hellas contributes to a structured, competence-based and impartial validation of professional skills.

Zürich, 27. Februar 2026 Ref. Ares(2026)2140265 - 26/02/2026 Skills Portability Initiative Call for Evidence: Swiss employers' association Acceptance of skills and qualifications across borders: What are, in your experience, the key obstacles to free movement of workers related to the acceptance, recognition and transparency of VET skills and qualifications?

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In a border region where the match between job opportunities and available workers is not well distributed on both sides in both nations, it may be interesting to look across the border. For the Euregio, this is topical and even a need to safeguard prosperity (and maintain businesses). Workers from one nation are often employable on the other side of the border.

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This response is submitted jointly by the MASTERY consortium (an Erasmus+ Forward-Looking Project on micro-credentials for green economy skills) and contributing organisations from 7 EU Member States, including VET providers, higher education institutions, public authorities and industry associations.

I'm a public employer and I'd like the concept of worker mobility to be more inclusive of public sector workers who, like me, would like to work in another EU country, expand their knowledge of a language other than their own, and perhaps even contribute and add value to other institutions.

The Federal Chamber of Tax Consultants (Bundessteuerberaterkammer, BStBK) welcomes the opportunity to comment, but nevertheless wishes to raise the following points with regard to the European Commission’s considerations: Refusal of automatic recognition: We reject the extension of automatic recognition under Directive 2005/36/EC to the profession of tax adviser through delegated acts.

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LUNIPSO (Union des entreprises à profit social) is the cross-sector and pluralist employers’ confederation representing social enterprises (non marchand) in French-speaking Belgium (Wallonia and the Wallonia-Brussels Federation). Unipso welcomes the European Skills Transferability Initiative as a key lever to address labour shortages by supporting labour mobility and the challenge of administrative simplification.

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1. The Value of Non-Formal Excellence in a Shifting Economy BDE welcomes the European Commissions focus on skills transparency and digitalisation. As a provider of non-formal adult education for refugees in Malta, we represent the frontline of skill acquisition for marginalised Third-Country Nationals (TCNs). Transparency must not be synonymous with formal accreditation.

ENGLISH----------------------------------------------------------- Unión Profesional: Contribution to the Public Consultation – Skills Portability Initiative February 2026 The Spanish association Unión Profesional, registered in the European Union Transparency Register under number 57238506728-24, with its office at Paseo General Martínez Campos, 15 (28010, Madrid), hereby submits its contribution to the Skills…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The EFBWW is particularly concerned that labour mobility is increasingly being instrumentalised in discussions on competitiveness, housing crisis and cross-border economic activities and promoted as a primary solution to labour shortages in the construction sector, as reflected in initiatives such as the European Single Market Strategy, the Strategy for Housing Construction and the proposed Construction Services…

European Family Businesses (EFB) would like to thank the European Commission for the opportunity to comment on the Skills Portability Initiative. The feedback can be found in the attached pdf document. As always, EFB remains open to discuss the topic at hand and offer further insights.

This response is submitted by the Swedish Electricians Union (Svenska Elektrikerförbundet), a trade union representing skilled workers in a safety-critical regulated profession. Temporary work during recognition: a major risk factor The initiative proposes pragmatic solutions under which third-country nationals may benefit from temporary job opportunities while their recognition process is still pending.

This response is submitted by the Swedish Electricians Union (Svenska Elektrikerförbundet), a trade union representing skilled workers in a safety-critical regulated profession. Risks of negative harmonization in regulated professions The initiative aims to modernize and expand the recognition processes under Directive 2005/36/EC, drawing on Articles 46, 53, and 62 TFEU.

This response is submitted by the Swedish Electricians Union (Svenska Elektrikerförbundet), a trade union representing skilled workers in a safety-critical regulated profession. Micro-credentials and de-skilling risks The initiatives emphasis on micro-credentials and the validation of non-formal and informal learning poses a serious risk to the integrity of comprehensive, social partner-developed vocational…

InnoEnergy welcomes the Skills Portability Initiative and its shift from qualification recognition toward competence transparency. Worker mobility across the EU depends on skills transparency, a shared language for skills, and trusted digital mechanisms that make skills comparable across borders. Skills must hold value across industries and Member States, requiring shared frameworks and recognition mechanisms.

The ASDITED Association of Technical Directors of Sport (Portugal) welcomes the initiative of the European Commission. We represent professionals responsible for the governance, safety and sustainability of public and private sports infrastructure.

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ETUCE Response to European Commission’s consultation on the Skills Portability Initiative 12 January 2026 The European Commission is preparing the so-called Skills Portability Initiative which was announced within the Union of Skills.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

There is a serious shortage of labour in many sectors in our territory, while foreign people, who are allowed to reside in the territory, have the skills they need. These talents remain untapped due to the lack of effective recognition of their achievements, which is a loss for our economy and public finances.

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The Association of Nordic Engineers (ANE), representing more than 500,000 STEM professionals across the Nordics, argues that Europe urgently needs a more precise and modern approach to STEM skills to remain competitive in strategic sectors. Today, the EU still treats STEM as one broad category, which obscures the specialised and rapidly evolving technical capabilities that industries depend on.

Please find attached the contribution on the Skills Transferability Initiative. This document is based on more than 20 years of support for people trained outside the European Union in their efforts to recognise qualifications and gain access to qualified employment.

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Přenositelnost dovedností Stanovisko HK ČR HK ČR vítá záměr Evropské komise posílit přenositelnost dovedností a kvalifikací v rámci EU i ve vztahu k třetím zemím. Dlouhodobý nedostatek pracovní síly, tlak zelené a digitální transformace a potřeba efektivnějšího fungování jednotného trhu podtrhuje naléhavost této iniciativy.

Filed in Czech · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Recognition of qualifications and skills of third-country nationals is increasingly relevant to the textile and apparel industry because demographic change, persistent shortages and the pace of industrial transformation are tightening labour markets in several regions and occupations. Skills portability policy that excludes third-country nationals risks missing an important dimension of labour market functioning.

Skills portability in the European textile and apparel industry is constrained less by the willingness of workers and employers to engage cross-border, and more by the practical difficulty of making skills and qualifications legible, comparable and trusted across national systems. A credible approach to skills transparency and digitalisation should therefore start from the realities of the ecosystem.

1. Greater harmonisation of training standards It would be useful to define in more detail the development of European reference curricula or shared guidelines. This would reduce substantial differences between national training pathways, limiting the use of compensatory measures and making recognition faster and more predictable. 2.

Filed in Italian · English published by the European Commission

The Portuguese Association of Liberal Professionals (ANPL) welcomes the European Commissions Skills Portabil¬ity Initiative as a timely and strategic response to profound transformations in Europes labour market.

Contribution by CONPEF (National Coordination of Experts and Forensic Experts), a professional association representing non-regulated PES professions, is a strategic step towards a more integrated, transparent and inclusive European labour market. The recognition of skills in formal, non-formal and informal settings meets the needs of many professionals working in unregulated but highly specialised sectors.

Filed in Italian · English published by the European Commission

I am very interested in and in favour of developing measures to improve the portability of skills and qualifications in the European Union, in particular as regards the recognition of professions not regulated by national professional registers (or regulated only in some Member States).

Filed in Italian · English published by the European Commission

FNV: General views on Skills Portability 1. Labour shortages in several industries highlight the need for better labour market where mobility can contribute to improved employability. The aim of the initiative should be to enhance employability and job quality and to ensure that the skills and qualifications of Europes workforce are fully valued. 2.

TÜV NORD Hellas welcomes the European Commissions initiative on skills portability and supports efforts to enhance transparency, trust and effective cross-border recognition of skills and qualifications within the European Union.

IDEA X welcomes the Skills Portability Initiative and its shift from qualification recognition toward competence transparency. Based on our practice in adult education, coaching and non-formal training delivery, we observe that labour mobility in Europe is limited not by the lack of skills, but by the inability of employers to interpret competences acquired outside formal education systems.

Skills portability – Getlink response |20.2.2026 Getlink welcomes the European Commission's initiative on the transferability of skills and its aim to ensure that qualifications and skills are transferable across national borders, thereby helping to make the EU a more attractive place for talent.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The document attached details the position of EFPA regarding: 1. Mobility of Psychologists under the terms set up by current Directives 2. Mobility of Psychologists can be enhanced though the adoption of common European Standards.

There is a major problem of recognition of qualifications and skills in the Wallonia Brussels Federation in Belgium. There is a serious shortage of labour and nothing has been put in place to remedy this. However, foreign persons authorised to reside on the territory have these skills. It would be advisable to recognise these qualifications and perhaps offer an update of the knowledge via a traineeship.

Filed in French · English published by the European Commission

Finance Denmark welcomes the fact that the Directorate General for Employ-ment, Social Affairs, Labour Mobility and Inclusion is exploring options to support the free movement of workers in Europe in order to strengthen the EUs competi-tiveness and address labour shortages across countries and sectors.

The Council of Bars and Law Societies of Europe (CCBE) represents the Bars and Law Societies of 46 countries and, through them, more than one million European lawyers. This position paper sets out the perspective of the legal profession in the context of the European Commissions public consultation on the forthcoming Skills Portability Initiative.

The municipality of Emmen is a border municipality, located on the border with the German Emsland and Grafschaft Bentheim. Border municipalities do not experience agglomeration benefits due to the border, which leads to less growth and employment. As the European Commission states in its Communication on border regions (COM2017) 534 final, pp.

The German Federal Chamber of Psychotherapists (Bundespsychotherapeutenkammer BPtK) expressly welcomes the initiative of the EU Commission to further develop the portability of skills within the EU and to modernise professional recognition procedures. The EU is founded on the freedom of movement.

The German Federal Chamber of Psychotherapists (Bundespsychotherapeutenkammer BPtK) expressly welcomes the initiative of the EU Commission to further develop the portability of skills within the EU and to modernise professional recognition procedures. The EU is founded on the freedom of movement.

The German Federal Chamber of Psychotherapists (Bundespsychotherapeutenkammer BPtK) expressly welcomes the initiative of the EU Commission to further develop the portability of skills within the EU and to modernise professional recognition procedures. The EU is founded on the freedom of movement.

TruMerit welcomes the European Commissions Skills Portability Initiative and submits the attached paper, Operationalising Skills Portability in Healthcare: A Practical Implementation Framework for the European Union as a concrete implementation proposal focused on regulated health professions.

The National Council of the Order of Midwives supports the mobility of health professionals within the European Union, as long as it fully guarantees the quality and safety of care. However, the current mechanism for automatic recognition of professional qualifications for midwives is satisfactory neither in principle nor in functioning.

Filed in French · English published by the European Commission

The National Council of the Order of Midwives supports the mobility of health professionals within the European Union, as long as it fully guarantees the quality and safety of care. However, the current mechanism for automatic recognition of professional qualifications for midwives is satisfactory neither in principle nor in functioning.

Filed in French · English published by the European Commission

The National Council of the Order of Midwives supports the mobility of health professionals within the European Union, as long as it fully guarantees the quality and safety of care. However, the current mechanism for automatic recognition of professional qualifications for midwives is satisfactory neither in principle nor in functioning.

Filed in French · English published by the European Commission

As part of Tipperary County Councils Local Authority Integration Team (LAIT), we meet with International Protection Applicants and Beneficiaries of Temporary Protection now living in Tipperary on a daily basis and observe persistent barriers relating to qualification recognition.

Confindustrias Position This is a crucial dossier for the Italian productive system: the demographic winter and the growing skills mismatch are costing billions of euros in lost GDP. A key priority for Italian companies is the attraction of talent from non-EU countries, through faster, more reliable and skills-based pathways. Key Proposals 1.

The ECEC represents over 300,000 legally authorized and highly qualified Chartered Engineering Consultants across Europe. Chartered engineering services are intellectual services including the conception, coordination, integration and long-term performance of buildings and the built environment.

The ETUC calls for a Skills Portability Initiative that strengthens workers rights, ensures fair mobility, and prevents wage and social dumping. The initiative must enhance employability and job quality while avoiding approaches that prioritise talent search and labour supply over decent work.

Law FEEDBACK: FROM THE CONSEJO GENERAL DE LA PSICOLOGÍA DE ESPAÑA (General Council of Psychology of Spain) 1. 2. 3. Have your say – Public Consultations and Feedback Published initiatives. Skills portability, action 1 – facilitating work mobility across the EU through skills transparency and digitalisation Feedback from: General Council of Psychology of Spain The General Council of Psychology is an official…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

100% of programme learning outcomes mapped to ESCO skills and occupations. ESCO alignment embedded in curriculum design, validation, and review processes. All micro-credentials issued with ESCO-tagged metadata to support interoperability with Europass and other digital credential infrastructures. Graduate competence frameworks reference DigComp competence areas and proficiency levels.

The Marburger Bund is a doctors association and trade union representing more 150,000 members in Germany. Since many years we demand that Germany should train enough doctors to ensure a proper functioning of our healthcare system which is, unfortunately, still not the case. Consequently, Germany relies on foreign-trained doctors who contribute significantly towards the healthcare of our population.

European Boating Industry (EBI) welcomes the Skills Portability Initiative and considers it highly relevant for addressing a persistent structural barrier within the EUs nautical tourism sector: the lack of effective mutual recognition of professional skipper qualifications for small commercial vessels (<24m).

COV, representing more than 35000 staff in education, recognises that the initiative can have a major impact on the labour mobility of teachers and education systems. Teaching is the foundation of quality education and should remain a highly demanding regulated profession. The COV opposes any attempt to deregulate the profession, or to lower qualification standards, when modernising recognition procedures.

Filed in Dutch · English published by the European Commission

It is a legitimate concern of the authorities responsible for recognising foreign professional qualifications in the German federal states to protect themselves against being overwhelmed by unnecessary applications.

Due to the federal tradition and the corresponding administrative structure, the federal states in Germany are responsible for the regulation and recognition of many professions, especially in the education, health and social sectors. The legal deadline for confirming receipt of an application is one month, and the deadline for deciding on the equivalence of the proven qualification is three months.

Please find attached DIGITALEUROPE's Priorities for Europe's Skills Agenda, among which the following recommendation: "DIGITALEUROPE supports the Skills Portability Initiative as a cornerstone of the EU Single Market. It should build on our call for a Digital Skills Passport incorporating industry-recognised qualifications, certifications, micro-credentials, digital badges and courses.

This Skills Portability Initiative addresses issues the European Union of Medical Specialists (www.uems.eu) has been working on for almost 70 years! The UEMS has all these years been working on harmonisation of postgraduate training (PGT), continuous medical education/continuous professional development (CME/CPD) and quality of medical practice.

This Skills Portability Initiative addresses issues the European Union of Medical Specialists (www.uems.eu) has been working on for almost 70 years! The UEMS has all these years been working on harmonisation of postgraduate training (PGT), continuous medical education/continuous professional development (CME/CPD) and quality of medical practice.

This Skills Portability Initiative addresses issues the European Union of Medical Specialists (www.uems.eu) has been workingon for almost 70 years! The UEMS has all these years been working on harmonisation of postgraduate training (PGT), continuous medical education/continuous professional development (CME/CPD) and quality of medical pratice.

ACCA welcomes the opportunity to respond to the European Commissions public consultation on the Skills Portability Initiative. We reaffirm our support for the ECs Union of Skills strategy and efforts to facilitate labour mobility. ACCA similarly supports the intent of the three action areas.

General Comments Need for the Skills Portability Initiative to reduce the overall regulatory and administrative burden experienced by planning authorities, practices and professional bodies rather than adding to it. What support will be provided to planning authorities, practices and professional bodies to implement digital credentials and recognition tools effectively?

The British Psychological Society recognises that currently there is a mismatch between those qualifying and working in Europe, to work in the UK. Whilst the consultation acknowledges difficulties in digital credentials and transparency of skills across EU member states, it is also important to acknowledge that UK residents position is further complicated by the post Brexit arrangements.

Ladies and Gentlemen, in response to the European Commission’s call for evidence on the Skills Portability Initiative, we would like to provide you with a position paper on the qualification for the safe operation of work machines. The qualification of work machine operators is a technical safety competence and not a professional qualification of an economic nature.

Filed in Polish · English published by the European Commission

The European Network of Podiatry in Higher Education (ENPODHE) welcomes the Skills Portability Initiative and strongly supports Measure 1 aimed at facilitating worker mobility through greater transparency and digitalisation of skills and qualifications. Podiatry represents a clear and underexplored example of the challenges that this initiative seeks to address.

In the context of the free movement of professionals within the European Union, the European Professional Card (EPC) scheme is an essential tool for high-mountain guides to work temporarily in other Member States. However, its current operation does not fully meet the objectives of administrative simplification and harmonisation pursued by the European Union.

Filed in French · English published by the European Commission

The simplification and acceleration of recognition procedures for qualifications and skills require a coherent digital-by-design model supported by mature, widely available technologies. Simple online portals, automated translation services and AI-assisted assessment toolsif deployed within a trusted EU public infrastructurecan substantially reduce administrative burden, increase transparency and ensure consistency…

Industry employers welcome the opportunity to comment on the European Commission’s work on the Skills Portability Initiative. On behalf of Sweden’s employers in the basic industry, we would like to stress the importance of a well-functioning internal market where labour mobility can take place efficiently, predictably and with high levels of trust between Member States.

Filed in Swedish · English published by the European Commission

EUCEN welcomes the initiative to enhance skills transparency and facilitate worker mobility across the EU. We would like to highlight the crucial role of universities and university lifelong learning (ULLL) units as trusted issuers of micro-credentials and as assessors of prior learning.

Digital credentials will only improve mobility and recognition across the EU if they are supported by secure, trusted verification systems that employers, universities and authorities can use quickly and confidently. In practice, the key risk today is not only paper-based diplomas, but the lack of consistent result authenticity and identity verification.

Ireland faces acute labour shortages across critical sectors such as construction, IT, engineering, logistics, sustainability, hospitality, healthcare and customer-facing roles, with employers reporting unprecedented difficulty in finding skilled workers. At the same time, thousands of migrants already living in Ireland possess qualifications and experience that match these needs but remain under-utilised.

As a front line worker working with migrants on a daily basis the issue of qualification recognition comes up frequently. New arrivals in Ireland are frustrated at the bureaucracy and red tape in place when it comes to the recognition of an overseas qualification. A more streamlined system across Europe needs to be introduced to make it easier for overseas qualifications to be recognised.

The character limit in the feedback field is not sufficient, so I am attaching a PDF file. In summary, the feedback I can provide is as follows. Based on our experiences at Taflan GmbH, the Skills Portability Initiative should explicitly address the gap between political objectives and administrative practice. First, recognition systems must systematically integrate employer-based competence assessments.

International recruitment of nurses is not a sustainable solution to nursing shortages, but at a time of pressing nursing shortages, EU legally binding harmonised rules for the recognition of qualifications of non-EU educated and trained nurses could support EU and European Member States in tackling the shortages in the short term.

ETUCE, representing 4.9 million teachers and education staff across Europe, acknowledges that the Initiative can significantly influence the labour market mobility of teachers and education systems. Teaching is among the most mobile regulated professions in the EU, with secondary school teachers ranked 2nd, primary school teachers 12th, and early childhood teachers 16th.

While legislative initiatives can play an important enabling role, we believe that the key added value of the SPI should lie primarily in the development of practical, interoperable tools that ensure comparability of skills and qualifications across all EU Member States.