General system of recognition (EU)

The general system is the default route in Directive 2005/36/EC. The European Commission describes it as based on equal treatment: if your qualification gives full access to a profession in one member state, another member state must recognise it for the same profession, subject to a comparison of training. Article 13 sets the basic rule, and Article 14 lets the host country require compensation measures where the training differs substantially.

• Professionals in regulated professions outside the seven sectoral ones, such as physiotherapists, radiographers, occupational therapists and speech and language therapists.
• Sectoral professionals who do not meet the conditions for automatic recognition, for example a pharmacist whose diploma is not listed in Annex V.
• Specialist doctors whose specialty is not listed, or not notified, and specialist nurses.
• Holders of a third-country qualification that a member state has recognised under its national rules, with three years of professional experience in that state (Articles 3(3) and 10(g)).

The authority compares the duration and content of your training, and the activities you may carry out under the same title at home, with what it requires. A difference counts only if it concerns knowledge and skills essential to the profession and the content differs significantly (Article 14(4)). Before imposing any measure, the authority must check whether your professional experience or formally validated lifelong learning, gained in any country, already covers the gap (Article 14(5)).

If it imposes a measure, the decision must state the level of your qualification and the level required, the substantial differences, and why your experience does not make up for them (Article 14(6)). Where a measure would not be enough, some countries can grant partial access to the profession instead.

1. You apply to the competent authority. The national assistance centre can tell you which body that is.
2. The authority acknowledges receipt within one month and asks for anything missing (Article 51).
3. It decides within three months of a complete file, which can be extended by one month, so four months in total.
4. If it imposes an aptitude test, you must be able to sit it within six months of that decision (Article 14(7)).
5. You can appeal a negative or late decision in the national courts.

Physiotherapists can apply electronically through the European Professional Card instead.

Many countries use the same logic for people trained outside the EU, under national law. Germany's Anerkennungsverfahren compares your training with a German reference occupation and lists substantial differences in a notice, often called a Defizitbescheid. The rules are similar, but the EU deadlines and the right to choose a measure do not automatically apply. Germany's federal recognition law, for instance, sets its own three-month decision period from a complete file, which can be extended once.