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A proposed deal between the UK and EU to allow lawyers, bankers or architects to work more freely across the continent would not solve post-Brexit mobility issues facing professionals, the bloc’s external auditor has warned.
Rachel Reeves, Labour’s shadow chancellor, has suggested London and Brussels negotiate mutual recognition to allow British professionals to use their skills more easily, as part of her plans to shift the UK closer to the EU over time.
But the European Court of Auditors found that extra exams, legal paperwork and additional fees mean workers face barriers moving country, even within the EU.
Each EU member state regulates an average of 212 professions, equivalent to about 5,700 professions across the entire bloc, from engineers and pilots to ski instructors, it said.
“We found huge procedural disparities between member states when they apply EU rules, to the detriment of those wishing to pursue a regulated profession elsewhere in the EU,” said Stef Blok, the ECA member responsible for the audit.
However, he said UK workers would still benefit from any mutual recognition deal. “The EU system is better than the experience for those coming from outside.”
The UK’s Labour party, which is leading the Conservatives ahead of Thursday’s election, said in its manifesto that it would seek to “tear down” barriers to trade with Europe, including striking deals on recognising qualifications. Reeves told the FT such a move would boost the UK services sector.
The existing EU-UK trade deal already contains a clause allowing both sides to strike deals on qualifications, but the EU Commission has already rejected an application to start talks over architects — in an indication of how difficult it will be to reach such deals will be in practice.
European officials have warned that any such deals are expected to require prolonged negotiations, whether Labour or the Conservatives are in power in the UK.
A recent report by the UK in a Changing Europe think-tank said the economic advantages of such agreements would be “minimal” overall.
Professional qualifications deals move notoriously slowly: it took nine rounds of negotiations spanning nearly a year to seal a deal for EU and Canadian architects to be able to work in each other’s countries. Under the deal, candidates still have to meet certain requirements such as 12 years’ training and experience and receive permission from local authorities, while EU architects in Canada have to complete a 10-hour online course.
Although the single market in theory enables free movement of labour, individual countries can be protective of national standards. They are entitled to lay down rules for access to a number of “regulated professions”, the ECA noted.
Healthcare workers are high on the list but tour guides, architects and lawyers are also regulated in most countries.
Governments could impose a test or an adaptation period, during which the profession can be exercised, but only under supervision. This can require payment. For instance, pilots wanting to fly in the Netherlands have to pay €17,500 in administrative fees.
The Czech Republic requires sworn, translated documents and a visit to the embassy.
Even after paperwork is filed, people can wait up to four months in Spain, France and Germany for a decision.
“There are many bureaucratic hurdles, usually unnecessary, sometimes intentional and sometimes just not thought through,” Blok told the FT.
He said it was vital that the EU made the progress smoother, suggesting the Commission should use its legal powers to force countries to improve their processes. “For a number of professions in a number of countries it works quite well.”
The ECA calculated that about 6 per cent of EU citizens aged 20-64 years who moved to another member state needed permission for a regulated profession — or 141,000 out of 2.26mn movers.