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Da: xfai da te originale 21/10/2011 08:29:04
per caso ti riferisci a: Agnieszka MatuszakEuropean CommissionDG Internal Market and ServicesFree movement of professionals (Unit E4)* European Commission, B-1049 BrusselsOffice: Rue de Spa 2 06/032, 1000 Brussels

Da: Italoabogado = Asino 21/10/2011 08:34:52
Basta ragliare. A studiare!

Da: iocivogliocredere 21/10/2011 09:27:09
Sei sempre qui a controllare interessi che non ti appartengono tu che inviti gli altri allo studio..
ma tu ne hai pratiche di clienti da studiare :) ?

Da: fai da te originale 21/10/2011 09:40:18
x Iocivoglio..... perchè mi hanno invitato non posso certamente postarlo qui. Tu che dici? Diciamo che in passato ho ricoperto qualche carica ...... e non escludo di ricoprirne di nuovo. Mandami una mail in privato ne parliamo come l'ho fatto con chiunque ho visto essere una persona seria ed onesta.
Ma di una cosa stai pur certo, la direttiva nuova c'è. Non è che facendo finta di nulla che le cose si risolvono. Qui se chiude la porta pure Roma ........ il titolo di abogado diventa una pezza da muro come quello di odontoiatra rumeno.

Da: wow 21/10/2011 09:52:35
ma che cazzo stai dicendo, ma sai almeno che la direttiva deve poi essere recepita?

ci son voluti 3 anni per recepire quella del 98.

Ti prego, falla finita che tra te e quello che si firma comme Avv.s. non so chi è peggio!

Da: iocivogliocredere 21/10/2011 09:56:48
Se fossi femmina ti direi : come sono afffffassscinanti questi uomini misteriosi.
Essendo maschietto.. ci devo pensare a cosa dirti :).
Cmq dimmi tutto ma non dirmi che sei "un certo" PierSilvio (questa non la sopporterei) XD !

ps serio: Anche io ho provato a dare un'occhiata veloce e non l'ho trovata : posti link gentilmente ?

Buon lavoro

E' disponibile l'App ufficiale di Mininterno per Android.
Scaricala subito GRATIS!

Da: iocivogliocredere 21/10/2011 09:59:41
ps @ FAI: ma se ti do la mail mi dai il biglietto dell'invito che voglio andare a mangiarli freschi i cavolini XD ?

Da: fai da te originale 21/10/2011 10:01:16
Draft Agenda
Public Conference on the Modernisation of the
Professional Qualifications Directive
Brussels, 7 November 2011
Charlemagne building
Rue de la Loi 170
1040 Brussels
Belgium
08.00 - 09.00 Registration
09.15 - 09:45 Opening of the Conference - Speech by Commissioner Barnier
followed by Questions / Answer session
09:45 - 10:15 Speech by a representative of the Polish Presidency of the Council
followed by Questions / Answer session
10.15 - 10.45 Speech by Malcolm Harbour MEP, Chairman of the Internal Market
and Consumer Protection Committee of the European Parliament
followed by Questions / Answer session
10.45 - 11.00 Coffee Break
11.00 - 12.30 PANEL: Impact of the recent educational reforms on the
Professional Qualifications Directive
a) Introduction by Paul Harris (to be confirmed), GHK presenting
outcome of an independent study
b) Further panellists:, Emilie Turunen MEP (Greens, DK), Lesley
Wilson (Secretary General of the European University
Association), Tillman Prinz (Chief executive, German Federal
Chamber of Architects), Robert Rochefort MEP (ALDE,
France) (to be confirmed)
12.30 - 13.30 Lunch break
13.30 - 14.45 PANEL: The public health dimension in the Directive
Panellists: Bernadette Vergnaud MEP (SD - France), Baroness
Young of Hornsey (House of Lords), Giovanni Leonardi (Deputy
Director General in Ministry of Health in Italy); Andrzej Rys (Director

Da: fai da te originale 21/10/2011 10:05:13
EUROPEAN COMMISSION
Brussels, 22.6.2011
COM(2011) 367 final
GREEN PAPER
Modernising the Professional Qualifications Directive
(Text with EEA relevance)
EN 1 EN
1. INTRODUCTION
EU citizens1 providing a wide range of professional services to consumers and business are
essential stakeholders in our economy. Gaining employment or providing services in another
Member State is a concrete example of how they can benefit from the Single Market. It has
long been recognised that restrictive regulation of professional qualifications has the same
stifling effect on mobility as discrimination on the grounds of nationality. Recognition of
qualifications obtained in another Member State has thus become a fundamental building
block of the Single Market. As highlighted in the Europe 2020 Strategy2 and the Single
Market Act3, professional mobility is a key element of Europe's competitiveness. Burdensome
and unclear procedures for the recognition of professional qualifications were identified in the
EU Citizenship Report 20104 as one of the main obstacles EU citizens still encounter in their
daily lives when exercising their rights under EU law across national borders. A
modernisation would also strenghten the position of the European Union in international trade
negotiations making regulatory convergence easier, and allowing the EU to obtain better
market access in third countries for EU citizens.
Mobility of professionals is still low in the EU. The number of complaints, SOLVIT cases and
questions raised with Your Europe Advice and analysis of these cases provide clear evidence
of a need to modernise the rules. In addition, intra-EU trade in services (including
professional services) represents only about 25% of overall trade within the EU. This share is
far too low when considered against the background of the overall importance of the services
sector to the EU economy (70% of GDP). More can be achieved.
Increased mobility would also respond to the challenge of filling high-skill jobs, as the active
population declines. According to the projections of the European Centre for the Development
of Vocational Training (Cedefop), 16 million more people will be needed to fill high-skill
jobs by 20205, which under current trends will lead to severe shortages of qualified
professionals. Some of these skills shortages could be filled by people with professional
qualifications obtained outside the EU, who currently face major problems in having their
qualifications recognised.
A projected shortage of one million health professionals is of particular concern. How
countries can better manage mobility of health professionals by further strengthening their
general workforce policies, and further elaborating workforce planning mechanisms will be
1 This also concerns third country nationals who enjoy rights under European legislation: family
members of EU citizens, long term residents, refugees, and "blue card" holders are treated in the same
way as EU citizens with respect to recognition of professional qualifications.
2 Communication from the Commission Europe 2020, A strategy for smart, sustainable and inclusive
growth - COM(2010) 2020, 3.3.2010.
3 Communication from the Commission to the European Parliament, the Council, the European economic
and social Committee and the Committee of regions, Single Market Act, Twelve levers to boost growth
and strengthen confidence, "Working together to create new growth" - COM(2011) 206, SEC(2011)
467.
4 EU Citizenship report 2010 "Dismantling the obstacles to EU citizens' rights" - COM(2010) 603,
27.10.2010.
5 Skill supply and demand in Europe: medium-term forecast up to 2020 (2010), available at
http://www.cedefop.europa.eu/en/Files/3052_en.pdf
EN 2 EN
subject of separate action by the Commission and the Member States6.
Enabling citizens to realise their individual right to work anywhere in the EU must been seen
in this wider context. To take full advantage of the freedom of movement, professionals must
have their qualifications easily recognised in other Member States7. It is therefore essential
that the Professional Qualifications Directive8 sets out clear and simple rules for the
recognition of professional qualifications. At the same time, the rules must ensure high quality
of services without themselves becoming an obstacle to mobility. The European Union has
already achieved a lot in this area: some professional qualifications, notably in the areas of
health, architecture, crafts, trade and industry are subject to automatic recognition; for all the
other professions, the principle of mutual recognition on the basis of a "general system" has
been introduced successfully. In 2005, these rules were complemented by a new lighter
regime to facilitate temporary mobility. These rules benefit millions of professionals in
Europe. It is estimated, that the system of automatic recognition on the basis of harmonised
minimum training requirements alone applies to 6.4 million citizens9.
In March 2010, the Commission launched an evaluation of the Directive which mobilised
many stakeholders: around two hundred competent authorities drew up experience reports in
2010 and around four hundred participants gave their views in a public consultation in early
2011. The Green Paper builds on this evaluation. It presents new ideas for facilitating
mobility in the Single Market, such as the European Professional Card (see part 2); it explores
ways to build on achievements (see part 3); and it sets out the options for the modernisation of
automatic recognition (see part 4). A broad consultation on these ideas will help the
Commission to assess the various options for the modernisation of the Professional
Qualifications Directive.
A legislative proposal to modernise the Directive is planned for the end of 2011.
2. NEW APPROACHES TO MOBILITY
2.1. The European professional card
Modernisation should draw on the latest technologies to offer new tools for mobility. These
technologies have the potential both to enable professionals to become more mobile and
improve information to consumers and employers about professionals' qualifications for the
services they offer. A European professional card could be built around fast communication
technologies of the 21st century to create a mechanism which will give it concrete and welltailored
effects under a modernised Professional Qualifications Directive. The Internal Market
Information system (IMI) could facilitate much faster cooperation between the issuing
Member State (the professional's country of departure) and the receiving Member State (the
country where the professional seeks establishment). Faster cooperation between the two
6 A further issue concerns sea-related regulated professions where the Commission intends to publish in
2012 a Communication on Blue Growth, sustainable growth from the oceans, seas and coasts. The
Commission is, in that perspective, interested to understand whether in this area any specific obstacles
to mutual recognition can be identified.
7 Difficulties linked with the recognition of professional qualifications are one of the obstacles to
professionals mobility within the EU, along others such as portability of pension rights, language
barriers etc.
8 Directive 2005/36/EC of the European Parliament and of the Council of 7 September 2005 on the
recognition of professional qualifications (OJ L 225, 30.9.2005, p. 22).
9 Internal Market Scoreboard, July 2010.
EN 3 EN
countries would enable a fast-track recognition process for the card holder. Cooperation via
the IMI should also be subject to deadlines which Member States should be bound to respect
in the future. In the same vein, temporary mobility could become much simpler for the cardholding
professional: any information obligations that the receiving country can currently
impose would become redundant with all the necessary information either featured on the
card itself or available from the country of departure which issued the card by means of the
fast electronic infrastructure.
Mobilising the Member State of departure
Under the current system, the receiving Member State is responsible for the verification of the
migrating professional's qualifications. This can create difficulties for the professional, who
may need to submit translations of various documents. It can also be a resource-intensive task
for the competent authority in the receiving Member State, which may not be familiar with
the way qualifications are acquired in other Member States. A European professional card,
issued by the competent authority in the Member State where the qualification is acquired,
and under the condition that the professional is entitled to practice, could facilitate the process
by increasing the role of the Member State of departure at an early stage.
When issuing such a card, the competent authority in the Member State of departure would
have to check that applicants hold the correct qualifications and satisfy any other conditions
as may be required under a modernised Directive, for example that they are legally
established or that their diplomas are authentic. This authority would also store the documents
which justified the issuance of the card and make them available to its counterpart in the
receiving Member State, as necessary. To ensure mutual trust, the card would not be issued by
any commercial entities. When a profession is not regulated in the Member State of departure
it would be up to that Member State to designate a competent public authority to issue the
card (e.g. contact points10 or NARIC centres11).
Under this system, authorities in the receiving Member State would not have to engage
administrative resources to verify all the information that has already been examined by the
Member State of departure. Verifying the validity of the card itself might be sufficient to
confirm that the holder can exercise the profession in the host Member State.
The Internal Market Information System (IMI) could be relied upon in this context as a "back
office" for cooperation between competent authorities. This would require that all competent
authorities that issue and verify the card are registered with the IMI, allowing them to
communicate with each other if they have any questions. A significant proportion of
competent authorities across the EU are already registered; others are expected to register by
the end of 2012.
Mobilising the receiving Member State
For the professional wishing to provide services on a temporary basis, a professional card
could substitute the administrative documents supporting prior declaration, which most
10 Article 57 of the Directive obliges Member States to designate a contact point in order to provide the
citizens and contact points of other Member States with information and to assist citizens in realising
their rights.
11 National Academic Recognition Information Centres (NARIC) assist citizens with issues related to
academic qualifications. For more information see
http://www.enic-naric.net/index.aspx?s=n&r=g&d=about#NARIC.
EN 4 EN
Member States require on the basis of Article 7 of the Directive. An e-mail indicating the
professional's card number could be sufficient. The card holder could even be exempted from
the prior declaration regime altogether, because the card containing the necessary information
could be sufficient. It could be shown to the authorities and the recipients of services in the
host Member State instead of sending a declaration. Temporary mobility would become much
simpler, while any necessary controls would still be possible.
Similar benefits could be achieved for professionals seeking automatic recognition of their
qualifications on the basis of harmonised minimum training requirements. A card could attest
that the professional's qualifications comply with the harmonised minimum requirements
under a modernised Directive. This could be verified by the issuing competent authority at the
time of application for a card in the Member State where the requisite evidence of formal
qualifications was awarded. The authority in the receiving Member State would no longer
have to verify the qualifications and would thus be in the position to issue a recognition
decision within a significantly shorter period of time (e.g. within two weeks instead of the
three months currently allowed under the Directive)12.
Even under the general system, where qualifications are checked on a case-by-case basis, a
card could simplify and speed up the recognition procedure, as initial verification would be
completed by the authority issuing the card. As a result, the procedures could be shortened to
a maximum of one month instead of the current maximum of four months13.
A professional card would also offer benefits to service recipients, notably in terms of
transparency. By presenting the card, professionals would offer a guarantee that they are
competent to exercise the profession. In addition, a system could be set up to allow consumers
and employers to verify the validity of the card (e.g. through direct contacts with the
competent authority).
The work of the steering group and pilot case studies
A European professional card would not be mandatory. Interested mobile professionals
should have the possibility, but no obligation, to apply for such a card. The Commission has
already set up a Steering Group on the professional card for selected parties who have
expressed an interest. It is composed of representatives of different professions, competent
authorities and trade unions. The Group began its work in early January 2011 and is expected
to put forward concrete conclusions by October of this year. The Group has been considering
the added value and possible legal effects of such a card. It also studied existing professional
card projects, as well as similar instruments that can be useful in the daily lives of citizens
(such as the European driving licence, the European health insurance card or the future
European Skills Passport). The Group devoted major attention to the challenges of
implementation, including the questions of the contents and format of such a card, as well as
the best way of ensuring its reliability. The results will be presented at the Single Market
Forum, which will take place on 3-4 October in Cracow, Poland.
12 While the reinforced role of the sending country may require the engagement of administrative
resources, such approach is likely to reduce the overall burden, as it should be easier for the sending
country to verify qualifications in its own country and languages and this should reduce costs incurred
through the repetition of verification.
13 Here again, the sending authority will spend more time verifying the information. However, the overall
procedure should be shorter, as the sending authority is best placed to do such checks (language
reasons, check of validity of administrative documents etc.).
EN 5 EN
In view of the differing conditions for access to and exercise of each profession, the Steering
Group has considered it useful to set up case studies involving a number of selected
professions: engineers, doctors, nurses, physiotherapists, and tourist guides.
Question 1: Do you have any comments on the respective roles of the competent authorities
in the Member State of departure and the receiving Member State?
Question 2: Do you agree that a professional card could have the following effects,
depending on the card holder's objectives?
a) The card holder moves on a temporary basis (temporary mobility):
- Option 1: the card would make any declaration which Member States can currently require
under Article 7 of the Directive redundant.
- Option 2: the declaration regime is maintained but the card could be presented in place of
any accompanying documents.
b) The card holder seeks automatic recognition of his qualifications: presentation of the card
would accelerate the recognition procedure (receiving Member State should take a decision
within two weeks instead of three months).
c) The card holder seeks recognition of his qualifications which are not subject to automatic
recognition (the general system): presentation of the card would accelerate the recognition
procedure (receiving Member State would have to take a decision within one month instead of
four months).
2.2. Focus on economic activities: the principle of partial access
Professionals can have difficulties with the recognition of their qualifications if the scope of
economic activities performed as part of the profession differs between their home Member
State and the Member State in which they seek establishment. This is the case, for instance,
for the profession of "snowboard instructor" which exists as a separate profession in certain
Member States but not in others where snowboarding is taught by ski instructors instead.
Sometimes the differences in the scope of economic activity covered by a profession in two
Member States are so large that professionals would have to undergo the full programme of
education and training in the host Member State, in order to make up for the differences in the
corresponding qualifications requirements, as in the example above. In considering this issue,
the Court of Justice developed the principle of partial access14. The Court held that Member
States must, under certain conditions, allow the partial taking-up of the profession on request
of the professional. However, according to case law of the Court, the protection of the
recepients of services and consumers in general may justify proportionate restrictions on the
freedom of establishment and the freedom to provide services if such measures are necessary
and proportionate in order to obtain the objective .
An insertion of this principle into the Directive would extend the safeguards offered to
professionals, such as deadlines by which Member States must issue recognition decisions,
also to professionals who meet the conditions for partial access.
14 Colegio de Ingenieros de Caminos, Canales y Puertos, Case C- 330/03 of 19 January 2006, European
Court reports 2006, p. I-801.
EN 6 EN
A modernised Directive could also confirm the criteria according to which the principle
would apply ("criteria-based approach"), in line with the jurisprudence. According to the
Court, the partial access principle applies where it is possible to objectively separate the
economic activity which the professional wishes to pursue in the host Member State from the
rest of the activities covered by a profession in that Member State. One of the decisive criteria
is whether that economic activity may be pursued, independently or autonomously, in the
Member State where the professional qualification was obtained. For example, an engineer
specialised in hydraulics in one Member State who wishes to work in a Member State where
his activities are performed by more broadly qualified engineers who also deal with roads,
channels and ports, might be able to gain partial access to the profession in the host Member
State. He would only be authorised to perform activities relating to hydraulics.
There can be exceptions from the principle, if justified by overriding reasons of general
interest, suitable for securing the attainment of the general interest objective and not going
beyond what is necessary in order to attain it.
Question 3: Do you agree that there would be important advantages to inserting the principle
of partial access and specific criteria for its application into the Directive? (Please provide
specific reasons for any derogation from the principle.)
2.3. Reshaping common platforms
Today only a limited number of professions enjoy the benefits of automatic recognition.
Many professions under the "general system" aspire to a similar mechanism which would
facilitate their mobility. Article 15 of the Directive offers the possibility to adopt common
platforms. The objective of these platforms would be to make compensatory measures (a test
or an adaptation period) redundant. It is not a tool for automatic recognition of qualifications.
Therefore, no common platform on compensation measures has been developed to date and
there is broad consensus that there is no foundation on which to base further progress. The
current concept of common platforms represents a failure. In the future, it should become
broader to open an avenue towards automatic recognition.
The Commission wishes to respond to the demand for easier mobility by allowing for
smoother recognition. A new approach to common platforms could address this objective.
They could operate in much the same way as the system of automatic recognition for doctors,
dentists, nurses, midwives, pharmacists, veterinary surgeons and architects, but without the
need for participation by all Member States, or even as many Member States as are currently
foreseen under Article 15. The threshold could be lowered to one-third of all Member States
(i.e. nine out of twenty seven) instead of two-thirds to improve the chances for the creation of
common platforms. It would also be made clear that any non-participating Member Stats
would be free to join a common platform at a later stage.
Any new platform would be subject to an internal market test. This would ensure that the
agreed conditions are proportionate and that the common platform does not contain excessive
detail so as to become an obstacle to the mobility of professionals from non-participating
Member States who wish to exercise their right to free movement in the Single Market. The
internal market test could be provided by the interested professional associations and may
help, in particular, to clarify whether professional experience would enable a professional
coming from a non-participating Member State to enter the profession in one of the
participating countries.
EN 7 EN
Finally, common platforms would have to be backed not only by professional organisations,
but in a second step, also by at least nine Member States. On the basis of a proposal of a
professional association and with the necessary support of a sufficient number of Member
States, the Commission could finally be in the position to endorse a common platform through
a delegated act, the framework for which could be laid down in the modernised Directive.
One example of ongoing work on a common platform is a common platform for ski
instructors.
Question 4: Do you support lowering the current threshold of two-thirds of the Member
States to one-third (i.e. nine out of twenty seven Member States) as a condition for the
creation of a common platform? Do you agree on the need for an Internal Market test (based
on the proportionality principle) to ensure a common platform does not constitute a barrier for
service providers from non-participating Member States? (Please give specific arguments for
or against this approach.)Professional qualifications in regulated professions
2.4. Professional qualifications in regulated professions
The Single Market Act provides for a further assessment of reserves of activities linked to
professional qualifications. It also calls for a review of the scope of regulated professions.
Today, the twenty seven Member States regulate around four thousand seven hundred
professions on the basis of a professional qualification. These professions can be grouped into
about eight hundred different categories. The Professional Qualifications Directive currently
offers a mutual recognition mechanism working overall for most of them. While Member
States are free to define qualifications requirements for access to certain professions as an
appropriate tool to achieve public policy objectives in relation to a given economic activity,
e.g. the need to ensure its security or its safety, in certain cases the qualifications requirements
may be disproportionate or unnecessary for the achievement of public policy objectives and
could lead to barriers to the freedom of movement of EU citizens. Indeed, there might be
cases where an EU citizen who already carries out an economic activity in his or her Member
State of origin is facing an unjustified and disproportionate qualification requirement in a host
Member State at such a level or of such a nature that the individual would not be in the
position to overcome the difficulties through a test or a stage (so-called compensation
measures) as foreseen in the Professional Qualification Directive nor be in the position to
claim partial access according to the Court jurisprudence (see section 2.2 on more information
on partial access). The citizen would, therefore, have no other choice than to undergo the
entire necessary training to acquire the domestic qualification in that host Member State.
Question 5: Do you know any regulated professions where EU citizens might effectively face
such situations? Please explain the profession, the qualifications and for which reasons these
situations would not be justifiable.
3. BUILDING ON ACHIEVEMENTS
3.1. Access to information and e-government
Professionals wishing to work in another Member State need to know and understand the
rules applicable to them. The evaluation of the Directive, notably the public consultation in
early 2011, has revealed this is a major problem for many stakeholders. In particular,
respondents have signalled insufficient clarity on which authority is in charge of recognising
their professional qualifications and which documents should be submitted. Insufficient
information on what to submit, and to which authority, often defeats the objective of getting a
EN 8 EN
quick decision by the host Member State.
A related challenge concerns the ability of professionals to enjoy a more efficient and more
convenient way to complete the application for the recognition of their professional
qualifications and receive the recognition decision through e-government sites.
A modernised Directive could foresee that each Member State make available a central on
line access point with complete information on competent authorities and document
requirements for the recognition of professional qualifications for all professionals, regardless
of their profession or the region in which they intend to exercise it. This would address the
first challenge. Knowing in advance exactly which documents need to be submitted would
bring more transparency for professionals and would avoid situations in which competent
authorities abstain from a formal decision on the grounds that the migrating professional's file
is not complete (see Article 51 (2) of the Directive).
A further step, building on the central access points, could consist in offering to professionals
the possibility of completing all the procedures related to the recognition of qualifications
online to meet the second challenge.
How could this solutions work address the two challenges in practice? The first option would
be to build on the National Contact Points foreseen under Article 57 of the Directive which
already inform and assist professionals seeking the recognition of their qualifications. At
present, their tasks primarily consist of offering advice by letter or telephone rather than
proactively ensuring access to information for EU citizens interested in professional mobility
on the required documents and the competent authority. In the future, the National Contact
Points could also organise the central access point to information and coordinate with the
competent authorities the e-government facilities enabling the completion of all formalities
online.
Another option would be to build on the points of single contact under the Services
Directive15. These are meant become fully fledged e-government portals allowing service
providers to easily obtain online any relevant information relating to their activities
(regulations, procedures, deadlines). In addition, the points of single contact allow service
providers to complete electronically all the administrative procedures necessary for the access
to and exercise of a service activity, including the procedures for the recognition of
qualifications, which is key to shorten procedures and reduce the burden linked with
administrative formalities. At present, the points of single contact are open to service
providers (including their seconded staff and self-employed professionals) covered by the
Services Directive16 but their scope could be extended should the Member State consider this
to be appropriate to cover all professional activities and not only those to which the Services
Directive applies. In the same vein, Member States could build on experience with the points
of single contact by further developing online facilities which would simplify and accelerate
procedures for the recognition of qualifications for all professionals, while respecting EU data
15 Directive 2006/123/EC of the European Parliament and of the Council of 12 December 2006 on
services in the internal market (OJ L 376, 27.12.2006, p. 36).
16 See the Commission staff working paper on the transposition and implementation of the Directive -
SEC(2010) 1292, 22.10.2010,
http://ec.europa.eu/internal_market/qualifications/docs/evaluation/staff-working-doc_en.pdf .
EN 9 EN
protection law, namely Directive 95/46/EC17.
Finally, in order to create synergies, it would be important to ensure close cooperation
between Member States' e-government facilities and the Your Europe portal which sets out to
become a single entry point for all useful information on EU rights18 and the challenges of
their implementation.
Question 6: Would you support an obligation for Member States to ensure that information
on the competent authorities and the required documents for the recognition of professional
qualifications is available through a central on line access point in each Member State? Would
you support an obligation to enable online completion of recognition procedures for all
professionals? (Please give specific arguments for or against this approach).
3.2. Temporary mobility
In 2005 a new regime was introduced to facilitate temporary provision of services. Under this
new regime, there is no obligation for the professional who wishes to provide services on a
temporary basis whilst maintaining establishment in the home Member State to undergo any
formal recognition procedures in the host Member State. Member States may only require a
prior declaration supported by a number of documents to be sent to the competent authority, if
necessary. A significant number of Member States make extensive use of this option.
There is a major issue in dealing with situations where a professional from a non-regulating
Member State moves temporarily to a Member State where the profession is regulated. In
such cases, the new regime is open only to those who can prove two years of professional
experience or provide evidence that they have followed "regulated education and training".
Some stakeholders are calling for more consumer choice which could be achieved by
widening the scope of the lighter regime. Others are afraid of abuse, such as "forum
shopping". The modernisation should strike the right balance between these legitimate
positions.
3.2.1. Consumers crossing borders
The two-years rule (Article 5(1) of the Directive) is generally accepted, because it protects
consumers in Member States where the profession is regulated. However, this rule can be
disproportionate in the case of consumers travelling from their country of origin to another
Member State and where such consumers have not chosen a professional in the Member State
they have travelled to but a professional from Member State they are coming from, for
example a group of tourists has chosen a tourist guide in the country where they depart from.
In this case, the professional concerned does not have any contact with local consumers in the
host Member State. Consequently, requiring a prior declaration and two years of prior
professional experience may not be justified on the grounds of consumer protection. The
respect for consumer choice should prevail over fears about "forum shopping", which do not
17 Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the
protection of individuals with regard to the processing of personal data and on the free movement of
such data (OJ L 281, 23.11.1995, p. 31).
18 The Your Europe portal (europa.eu/youreurope) is developed by the Commission, in partnership with
the Member States. The Editorial Board of Your Europe, which is composed of representatives of
Member States, must ensure that relevant national-level information is available through Your Europe,
and that proper links exist between Your Europe and national information portals.
EN 10 EN
appear to be relevant in these situations19. A prior declaration requirement would thus appear
to be unnecessary. Consumer choice would only be limited where public health or consumer
safety risks already justify a prior check of qualifications (as per Article 7 (4) of the current
Directive).
Question 7: Do you agree that the requirement of two years' professional experience in the
case of a professional coming from a non-regulating Member State should be lifted in case of
consumers crossing borders and not choosing a local professional in the host Member State?
Should the host Member State still be entitled to require a prior declaration in this case?
(Please give specific arguments for or against this approach.)
3.2.2. The question of "regulated education and training"
Professionals who completed "regulated education" are also exempt from the requirement of
two years' professional experience. The Directive defines "regulated education" rather
restrictively, as education which involves training specifically geared towards the pursuit of a
given profession, with reference to specific cases mentioned in Annex III of the Directive.
However, the world of education is moving and the Directive needs to keep pace with these
changes. In order to enhance employability in a lifelong learning perspective, education and
training policies increasingly aim at developing general "transferable" skills (e.g.
communication, management), in addition to specific job-related skills (technical skills). In
this context, it may not seem justified to limit the notion of regulated education and training to
those specifically geared to a certain profession (see Article 3(i) (e) of the Directive). The
notion of regulated educationcould be extended to encompass any education and training
recognised by a Member State and relevant to the profession. The Europass Diploma
Supplement20 or the Europass Certificate Supplement21could be used by training institutions
to give information on the contents and objectives of the relevant programmes. With a revised
definition of regulated education and training, suitably educated professionals could benefit
from the lighter temporary mobility regime in larger numbers. At the same time, Member
States would be entitled to continue requiring an annual prior declaration under a modernised
Directive (except in cases where the professional card makes this redundant).
Question 8: Do you agree that the notion of "regulated education and training" could
encompass all training recognised by a Member State which is relevant to a profession and
not only the training which is explicitly geared towards a specific profession? (Please give
specific arguments for or against this approach.)
19 Ideally these professionals would be equipped with a European professional card.
20 The Europass Diploma Supplement is issued to graduates of higher education institutions along with
their degree or diploma. It helps to ensure that higher education qualifications are more easily
understood, especially outside the country where they were awarded. see
http://europass.cedefop.europa.eu/europass/home/vernav/InformationOn/EuropassDiplomaSupplement.
csp;jsessionid=43770C133C7D2B78EA4522BF5ABFF581.wpc1
21 The Europass Certificate Supplement is delivered to people who hold a vocational education and
training certificate; it adds information to that which is already included in the official certificate,
making it more easily understood, especially by employers or institutions outside the issuing country.
For more information see
http://europass.cedefop.europa.eu/europass/home/vernav/InformationOn/EuropassCertificateSupplemen
t.csp;jsessionid=43770C133C7D2B78EA4522BF5ABFF581.wpc1
EN 11 EN
3.3. Opening up the general system
3.3.1. Levels of qualification
Article 11 of the Directive stipulates five levels of qualification which are based on the type
and duration of training. When a professional applies for the recognition of his or her
qualifications for a profession under the general system, the competent authority must use
these levels in order to determine if the applicant can benefit from the Directive. If there is a
difference of two or more levels between the qualification of the professional and the
qualification required in the host Member State, the Directive does not currently apply.
The levels defined in Article 11 might overlap with the eight levels of the European
Qualifications Framework (EQF) which is based on "learning outcomes", once the latter is
implemented in 201222. The coexistence of two classification systems creates a risk of
confusion for competent authorities and other stakeholders. A study commissioned by DG
Internal Market and Services is also currently assessing the benefits and limits of these
different systems of classification for the purpose of recognition. The results of this study will
be available in the autumn.
A possible way forward could be to avoid any classification of qualifications that excludes
certain professionals from the scope of the Directive. A possible solution could be to delete
the levels of qualifications in Article 11 (as well as Annex II which is linked to Article 11).
This would mean that competent authorities would no longer determine the eligibility of an
applicant according to pre-defined levels of qualifications but would focus on the
identification of substantial differences in training to decide whether compensation measures
are necessary. As a consequence, competent authorities could no longer refuse applications
for recognition on the grounds of a difference in the level of qualifications, such as between a
university diploma and secondary education. Neither could they exclude professionals from
recognition of qualifications on the basis of professional experience attested by a Member
State (as currently provided for in Article 11 (a) of the Directive). Deletion of such
classifications would also give more discretion to Member States.
Question 9: Would you support the deletion of the classification outlined in Article 11
(including Annex II)? (Please give specific arguments for or against this approach).
3.3.2. Compensation measures
Deleting Article 11 carries the risk of more compensation measures. Should Article 11 be
deleted, a possible option could be to recalibrate the system of compensation measures in four
steps:
1) Article 14 (1) of the Directive defines the conditions according to which the host Member
State can impose compensation measures. One of these conditions relates to the duration of
training. A difference in the duration of training of at least one year in itself is currently a
justification for compensation measures. It is questionable whether Article 14 (1) a of the
Directive is still justified.
2) Article 13(2) of the Directive requires professionals to have at least two years of
professional experience if their profession is not regulated in their home Member State. If
22 The "experience reports" and the reactions to the public consultation suggest that the application of the
system on the basis of these predefined levels is seen as overly complex.
EN 12 EN
they do not fulfil this requirement, they cannot currently benefit from the "general system".
There is no reason why professionals with less professional experience should be excluded.
The host Member State would need in any event to assess their existing qualifications,
including their professional experience. If the qualifications are substantially different from
the nationally applicable requirements, the host Member State could impose appropriate
compensation measures. Article 13 (2) of the Directive would be deleted accordingly.
3) The Commission has received a lot of complaints from citizens against competent
authorities imposing disproportionate compensation measures. If a modernised Directive does
no longer contain a classification,a new safeguard could be introduced in the modernised
Directive to protect EU citizens against arbitrary compensation measures. When imposing a
compensation measure on an applicant, the competent authority in the host Member State
could explicitly justify its decision with regards to:
a) the substantial differences between the training of the applicant and the training required in
the host Member State (specifically, which elements of the training required in the host
Member State are insufficiently covered by the training of the applicant and why they are
considered as "substantial differences")
b) why these substantial differences prevent the professional to exercise his profession in the
host Member State.
4) Finally, in order to facilitate the implementation of compensation measures, essential
provisions of the Code of Conduct for national administrative practices falling under the
Directive23 (such as the requirement for competent authorities to offer aptitude tests at least
twice a year) could be made mandatory. However, for the remaining parts, the Code of
Conduct should not become mandatory.
Question 10: If Article 11 of the Directive is deleted, should the four steps outlined above be
implemented in a modernised Directive? If you do not support the implementation of all four
steps, would any of them be acceptable to you? (Please give specific arguments for or against
all or each of the steps.)
3.3.3. Partially qualified professionals
The Directive facilitates mobility of fully qualified professionals. It currently does not apply
to people who have finished their studies, but are not yet fully qualified for the independent
pursuit of their profession. However, more and more people wish and should be able to
benefit from the internal market by completing a remunerated supervised practice abroad. The
Court of Justice clarified in the Morgenbesser case24 that the Treaty rules on free movement
apply to such cases and that Member States cannot, as a matter of principle, prevent people
from doing a remunerated supervised practice if they offer the possibility to their own
nationals. Member States must compare the qualifications of the applicant to those required
nationally with the view to assessing whether they are, if not identical, at least equivalent.
In line with the Morgenbesser jurisprudence, two principles could be confirmed in a
modernised Directive: The procedural safeguards of the Directive could be extended to
graduates from academic training who wishes to complete a period of remunerated supervised
practical experience in the profession abroad, provided that supervised practice is offered to
23 See: http://ec.europa.eu/internal_market/qualifications/docs/future/cocon_en.pdf.
24 Court of Justice 13 November 2003, Case C-313/01, Morgenbesser, ECR I-13467. (This judgement
was confirmed by the Court's judgement in Case C-345/08, Peśla v. Justizministerium Mecklenburg-
Vorpommern.)
EN 13 EN
nationals of the host Member State. This concerns, in particular, the deadlines applicable to
competent authorities for taking a decision, but also the obligation to acknowledge receipt of
the application within a certain timeframe and inform the applicant of any document missing
from their file. At the same time, the Directive could make clear that the country of origin
cannot refuse, as a matter of principle, to recognise a traineeship on the sole grounds that it
was conducted abroad. The procedural safeguards of the Directive could apply in this context
too.
Question 11: Would you support extending the benefits of the Directive to graduates from
academic training who wish to complete a period of remunerated supervised practical
experience in the profession abroad? (Please give specific arguments for or against this
approach.)
3.4. Exploiting the potential of IMI
3.4.1. Mandatory use of IMI for all professions
Cooperation between Member States via IMI is already daily practice. However, it is not
mandatory for the competent authorities for professionals whose activities are excluded from
the Services Directive. Feedback received from the competent authorities in the experience
reports in 2010 and the public consultation showed broad support for a mandatory use of the
system, beyond the professions covered by the Services Directive. A possible way forward in
the context of the modernisation of the Directive could be to ensure all competent authorities
respond via IMI to queries from their counterparts in other Member States25.
3.4.2. Alert mechanism for health professions
More importantly, a more proactive form of cooperation could be introduced: An alert
mechanism already exists for the professions covered by the Services Directive allowing
competent authorities to inform each other, under certain conditions, of any service activities
that might cause serious damage to the health or safety of persons or the environment. As a
consequence, the activities of a craftsman currently fall under this alert mechanism but not
those of health professionals who are outside the scope of the Services Directive.
Which solution is best suited for health professionals? The first option would be to apply the
same alert mechanism which applies to professions covered by the Services Directive to
health professionals: an alert would thus be limited to circumstances where there is clear
evidence that a health professional is migrating to another Member State though he has been
subject to sanctions barring him from exercising his profession in the Member State of origin.
The alert would be limited to the specific Member States where there is sufficient likelihood
of risks or damage occurring, which means considering any factors that might indicate that the
professional is likely to be active in other Member States. Another option which would
protect patients in a much more effective way would be to introduce an obligation to launch
an alert to all Member States once a migrating health professional loses his right to practise
due to sanctions in a Member State. Any measure taken in this respect should be in line with
25 To the extent this cooperation entails the processing of personal data, it is necessary to comply with
relevant EU law, as outlined by article 56.2 of the Professional Qualifications Directive, with reference
in particular to Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995
on the protection of individuals with regard to the processing of personal data and on the free movement
of such data (OJ L 281, 23.11.1995, p. 31).
EN 14 EN
the Charter of Fundamental Rights in particular with the protection of personal data and the
right to an effective remedy.
Question 12: Which of the two options for the introduction of an alert mechanism for health
professionals within the IMI system do you prefer?
Option 1: Extending the alert mechanism as foreseen under the Services Directive to all
professionals, including health professionals? The initiating Member State would decide to
which other Member States the alert should be addressed.)
Option 2: Introducing the wider and more rigorous alert obligation for Member States to
immediately alert all other Member States if a health professional is no longer allowed to
practise due to a disciplinary sanction? The initiating Member State would be obliged to
address each alert to all other Member States.)
3.5. Language requirements
Under Article 53 of the Directive, professionals must have the language knowledge necessary
to perform their activities in the host Member State. In this context, Member States must take
due account of the principle of proportionality which excludes systematic language tests.
Testing the language knowledge of EU citizens interested in professional mobility on a caseby-
case basis may be a legitimate way of safeguarding the interests of consumers and patients.
However, systematic language testing can become a means of unfairly preventing foreign
professionals from accessing the right to perform a professional activity, if applied
disproportionately. The main responsibility to ensure that all necessary professional language
skills are acquired lies with the employers.
A public debate on language requirements for health professionals is ongoing in a few
Member States. The issue of language skills of health professionals is gaining more
importance as migration of health professionals increases, and it is particularly acute in the
case of health professionals benefiting from automatic recognition who come into direct
contact with patients. Should they be subject to language tests? If so, at which point?
- One option would be to clarify the Code of Conduct26, which would be more conducive to
future adaptations.
- Another option would be to introduce into the Directive a rule specifically applicable to
health professionals with direct contact with patients. This provision would allow a one-off
control of the necessary language skills before the health professional first comes into direct
contact with patients.
Question 13: Which of the two options outlines above do you prefer?
Option 1: Clarifying the existing rules in the Code of Conduct;
26 Currently, Member States can control that professionals have the language knowledge necessary for
performing their activities, but they must do it in a proportionate way. This means that they cannot
subject systematically foreign professionals to language tests. Professionals should be able to prove
their language knowledge by other means (e.g. diploma acquired in the relevant language, professional
experience in the country, language certificate etc.). This means also that the level of language
knowledge required varies according to the type of activity and the framework in which it will be
conducted. Also the language control can only take place after the end of the recognition procedure and
cannot be a reason for refusing recognition of professional qualifications as such.
EN 15 EN
Option 2: Amending the Directive itself with regard to health professionals having direct
contact with patients and benefiting from automatic recognition.
4. MODERNISING AUTOMATIC RECOGNITION
4.1. A three-phase approach to modernisation
The Professional Qualifications Directive provides for a set of harmonised minimum
conditions for the training of doctors, dentists, general care nurses, midwives, pharmacists,
veterinary surgeons and architects. These minimum training requirements have been the basis
for automatic recognition for many years. The system of automatic recognition for these
professions is widely seen as a success. However, some of the training conditions themselves
date as far back as thirty years and many stakeholders call for the Directive to be modernised.
A modernised Directive should retain the basic principles of automatic recognition as a
starting point, with a flexible mechanism for updating the specific training requirements. This
mechanism could then be used to gradually build the ongoing educational reforms into the
automatic recognition regime. At the same time, the modernisation needs to take into account
continuing scientific and technical progress. Therefore, modernisation could be achieved in
three phases:
In the first phase, the Directive itself could be amended to clarify and adapt the foundations
of the training requirements, such as clarifying minimum training periods and strengthening
the measures which underpin the quality of the services offered by professionals.
Furthermore, it is necessary to change the institutional framework to replace the current
comitology system by either implementing acts or delegated acts27, in line with the Treaty on
the Functioning of the European Union The Council of Ministers and the European
Parliament would - ideally - decide on these changes, upon a proposal of the Commission to
be presented before the end of 2011. The Single Market Act of 13 April suggests that political
agreement on this phase be achieved by the end of 2012.
In the second phase, the framework of newly introduced implementing or delegated acts
would be used to update the existing training subjects for all professions concerned but also to
develop sets of competences, where necessary. (In this regard, it should be noted that the
Commission is already empowered to act under the existing comitology procedure.) Changes
in these areas would require upstream involvement from competent authorities which have
already started networking to build expertise and successfully assisted the Commission in
evaluating the current Directive in 2010. This second phase would commence in 2013 and
could be completed in 2014.
Finally, in the third phase, the harmonisation of minimum training requirements could be
further optimised, if necessary, for example by moving from a system of training hours to the
use of the European Credit Transfer and Accumulation System (ECTS)28 across Member
States in order to facilitate automatic recognition in the future. An ongoing external study on
the impact of educational reforms29 will assess the potential merits of using ECTS points in
this area. Depending on the outcome of the study, a mechanism could be envisaged to clarify
the minimum number of years specified in a modernised Directive in terms of equivalent
27 See Articles 290 and 291 of the Treaty.
28 For more information see http://ec.europa.eu/education/lifelong-learning-policy/doc48_en.htm.
29 The study carried out by GBP will be published in October.
EN 16 EN
number of ECTS points. However, this would require further efforts and engagement on the
part of the universities and the professionals. The first assessments could start in 2014.
Question 14: Would you support a three-phase approach to modernisation of the minimum
training requirements under the Directive consisting of the following phases:
- the first phase to review the foundations, notably the minimum training periods, and
preparing the institutional framework for further adaptations, as part of the modernisation of
the Directive in 2011-2012;
- the second phase (2013-2014) to build on the reviewed foundations, including, where
necessary, the revision of training subjects and initial work on adding competences using the
new institutional framework; and
- the third phase (post-2014) to address the issue of ECTS credits using the new institutional
framework?
4.2. Increasing confidence in automatic recognition
In their experience reports, many competent authorities called for a strengthening of the
system of automatic recognition. Some of them argue that more harmonisation of the
minimum training periods in the Directive, for example by introducing a number of training
hours or clarifying whether both years and training hours should apply, is necessary. Another
way forward would be to consider which body or authority at national level could take more
responsibility in ensuring that the contents of the training leading to a given professional title
fulfil the requirements of the Directive at all times.
4.2.1. Clarifying the status of professionals
The Professional Qualifications Directive provides for a set of harmonised minimum
conditions for the training of doctors, dentists, general care nurses, midwives, pharmacists,
veterinary surgeons and architects. These minimum training requirements are currently the
sole basis for automatic recognition of the qualifications of these professionals. Diplomas
attesting to the fulfilment of the minimum training requirements are sufficient for their
holders to become established in a Member State other than that in which their qualifications
were obtained. However, situations may arise in which diploma holders lose their right to
exercise the profession for which they were qualified in their home Member State (for
instance because they failed to comply with national requirements on continuous professional
development).
There is currently a gap in the Directive. In the case of temporary provision of services,
professionals are obliged to demonstrate that they have the right to exercise in their home
Member State and are not prohibited from exercising the profession, for instance because they
did not fulfil domestic requirements related to continuing professional development. There is
no explicit provision for a similar requirement in the case of establishment. It could be logical
to extend this requirement to cases where a professional wishes to establish himself on a
permanent basis in another Member State. This should for instance prevent doctors who are
no longer authorised to practice in one Member State from migrating to another.
EN 17 EN
Question 15: Once professionals seek establishment in a Member State other than that in
which they acquired their qualifications, they should demonstrate to the host Member State
that they have the right to exercise their profession in the home Member State. This principle
applies in the case of temporary mobility. Should it be extended to cases where a professional
wishes to establish himself? (Please give specific arguments for or against this approach.)Is
there a need for the Directive to address the question of continuing professional development
more extensively?
4.2.2. Clarifying minimum training periods for doctors, nurses and midwives
At present, for some sectoral professions, the minimum duration of training is expressed in
terms of years or training hours. This can give rise to misunderstanding whether the two
criteria constitute two options or if they should be applied together. Many stakeholders
suggest combining the two criteria. A modernised Directive could clarify this for doctors,
nurses and midwives for which the two conditions are already established but presented as
options.
Question 16: Would you support clarifying the minimum training requirements for doctors,
nurses and midwives to state that the conditions relating to the minimum years of training and
the minimum hours of training apply cumulatively? (Please give specific arguments for or
against this approach.)
4.2.3. Ensuring better compliance at national level
Automatic recognition for the professions for whom minimum training requirements have
been harmonised, is granted on the basis of professional titles awarded to members of the
professions, following the fulfilment of the minimum training contents prescribed by the
Directive. However, training contents evolve over time. In addition, many universities have
been implementing reforms under the Bologna process30, which is leading to many changes,
such as moving towards student-centred learning. This raises the question of how Member
States can, in the future, ensure that universities and other educational establishments follow
the framework set by the Directive in the light of continuing reforms.
Another challenge relates to Member States notifying the Commission of new developments,
notably new professional titles awarded in the Member State. In practice, such information
often arrives only once the graduates concerned leave the universities with their diplomas,
which limits the ability for some of the graduates to benefit from automatic recognition or at
least creates great uncertainty about free movement.
In order to address these two issues, a modernised Directive could contain the requirement for
Member States to notify new changes to diplomas as soon as they are accredited by an
accreditation institution or approved by other public bodies, thus well before students
graduate with the notified diplomas. The designated bodies (which would not necessarily need
to be newly created) would assume a national compliance function ensuring that the
harmonised minimum training requirements under the Directive are respected; a relevant
report from the body performing the national compliance function could accompany any
30 The Bologna Process was launched in 1999 in order to ensure more comparable, compatible and
coherent systems of higher education in Europe. For more information see http://www.ehea.info/.
EN 18 EN
notifications. These changes would not only enable young graduates to have more confidence
that they can benefit from automatic recognition but also enhance trust between Member
States.
Question 17: Do you agree that Member States should make notifications as soon as a new
program of education and training is approved? Would you support an obligation for Member
States to submit a report to the Commission on the compliance of each programme of
education and training leading to the acquisition of a title notified to the Commission with the
Directive? Should Member States designate a national compliance function for this purpose?
(Please give specific arguments for or against this approach.)
4.3. Doctors: Medical Specialists
The Commission received numerous comments on specialist training, primarily centring on
two issues. First, automatic recognition can currently only be extended to new specialities, if
the speciality exists in at least two fifths of the Member States. This threshold could create a
disincentive for innovation and limit the opportunities for inserting new medical specialities
into the Directive. It could be appropriate to lower the threshold of the number of Member
States required from two fifths to one third. In this way, the threshold for the insertion of new
specialities into the Directive would correspond to the threshold proposed for common
platforms (see section 2.3).
Question 18: Do you agree that the threshold of the minimum number of Member States
where the medical speciality exists should be lowered from two-fifths to one-third? (Please
give specific arguments for or against this approach.)
The second issue concerns the general framework for organising specialist training. The
Directive leaves little room for recognition of prior learning as part of training on courses
which are of at least an equivalent level to the training for a given speciality. This is of
particular relevance to specialities which have grown out of internal medicine or general
surgery31. If a doctor has followed a specialist training and afterwards follows another
specialist training, he or she would, in principle, have to follow the full training programme
for the second speciality, from the very start. The modernisation of the Directive could be an
opportunity to give Member States the possibility of granting partial exemptions from parts of
specialist training, if that part of the training has been followed already in the context of
another specialist training programme.
Question 19: Do you agree that the modernisation of the Directive could be an opportunity
for Member States for granting partial exemptions if part of the training has been already
completed in the context of another specialist training programme? If yes, are there any
conditions that should be fulfilled in order to benefit from a partial exemption? (Please give
specific arguments for or against this approach.)
31 As regards internal medicine, this concerns the following 11 specialties: immunology, rheumatology,
respiratory medicine, gastroenterology, cardiology, endocrinology, geriatrics, renal diseases, general
haematology, communicable diseases and clinical oncology. Closely linked to general surgery could be
seen the following 11 specialties: Plastic surgery, thoracic surgery, paediatric surgery, vascular surgery,
gastroenterological surgery, neurological surgery, orthopaedics, maxillo-facial surgery, stomatology,
dental, oral and maxillo-facial surgery and urology.
EN 19 EN
4.4. Nurses and midwives
The admission requirement for nurse training is currently minimum ten years of general
education (the same requirement applies to midwifery training under the so-called route I
training (Article 40 (2) a). However, the nursing profession has significantly evolved in the
last three decades: community-based healthcare, the use of complex therapies and constantly
developing technology presuppose the capacity for more independent work by nurses. In
several Member States, as a result of the shortage of doctors, nurses and midwives are
expected to perform tasks which were previously undertaken only by doctors. There is a
concern that students who enter nursing school after only ten years of general school
education do not have the necessary basic skills and knowledge to start a training which
should prepare them to meet complex healthcare needs. One option would therefore be to
require that Member States only allow admission to nursing training course for candidates
who have completed minimum twelve years of general education (as the same should apply to
'route 1' midwifery training). This requirement exists already in many Member States. The
other option would be to maintain the status quo.
Question 20: Which of the options outlined above do you prefer?
Option 1: Maintaining the requirement of ten years of general school education
Option 2: Increasing the requirement of ten years to twelve years of general school education
4.5. Pharmacists
The traditional role of pharmacists is changing from mere supply of medicine to a more direct
involvement with the patient, including counselling, providing information and even
reviewing, monitoring and adapting the treatment when needed. The community pharmacy is
becoming more important. Several interested parties suggest expanding the list of professional
activities a pharmacist is authorised to perform in the Member States, provided in Article
45(2) of the Directive, to reflect these changes. Interested parties most often request the
inclusion of "pharmaceutical care", "community pharmacy" and "pharmacovigilance" as new
professional activities. In addition, many stakeholders propose that that the Directive (current
Article 44(2)(b)) provide for a mandatory period of practical training of six months, directly
after completing academic training, to prepare future pharmacists for their role.
Another question is whether Member States should be entitled to ban fully qualified
pharmacists, who obtained their qualifications in another Member State, from opening new
pharmacies. Article 21 (4) of the Directive currently allows Member States not to give effect
to automatic recognition of a pharmacist's qualifications for the setting up or management of
new pharmacies, including those which have been open for less than three years. This result is
at odds with the general principle of automatic recognition and represents a discrimination
against EU pharmacists. Discrimination against EU citizens from other Member States is
incompatible with the Single Market. Ireland has already given up the application of this
derogation and the UK intends to abandon it by this summer. With the view to promoting free
movement of pharmacists and giving full effect to the principle of automatic recognition it is
proposed that this provision could be deleted. In any event, Article 61 of the Directive already
allows for derogations if there is a genuine need.
EN 20 EN
Question 21: Do you agree that the list of pharmacists' activities should be expanded? Do
you support the suggestion to add the requirement of six months training, as outlined above?
Do you support the deletion of Article 21(4) of the Directive? (Please give specific arguments
for or against this approach.)
4.6. Architects
In many Member States, universities offer at least five-year curricula in architectural studies.
The Directive does not present any obstacles to this trend: the training requirements of four
years academic training for architects, defined in Article 46 of the Directive, are only the
minimum, allowing Member States and universities to apply higher standards in educating
future architects. Nonetheless, the professional organisations representing architects, suggest
that the minimum duration of training under the Directive could be increased from four to five
years to reflect the evolution of the profession.
The proposal to harmonise the five-year requirement at EU level raises challenging questions.
Firstly, the Commission is not in the position to confirm which of the diplomas already
published in the Directive on the basis of their compliance with its current provisions attest to
training of five years. As a result, harmonising the minimum duration of training at five years
would necessitate an acquired rights regime for architects whose training started (or will have
started) before the entry into force of a modernised Directive in 2012 or 2013, in addition to
the already existing acquired rights regime for architects trained before the entry into force of
the first Directive on architects in 1985 (see Article 49 of Directive 2005/36/EC in
conjunction with Annex VI).
Secondly, this solution would significantly limit flexibility without addressing another
genuine problem related to mobility: how to take account of supervised professional practice,
an aspect of architectural education which is already recognised in many Member States as an
important feature of training architects?
Against this background, there appear to be two options:
The first option would be to retain the existing requirement of four years;
The second option would be to bring the Directive's provisions closer to the existing situation
in most Member States, whilst allowing for a degree of flexibility for each of them: in order to
benefit from automatic recognition, architects would have to attest to either at least five years
of academic training followed by a minimum of one year of supervised practical experience
or a minimum of four years of academic training with a minimum two years of supervised
practical experience. As a consequence, it would take a minimum of six years to become a
fully qualified architect in the European Union and this would always include supervised
practice.
Question 22: Which of the two options outlined above do you prefer?
Option 1: Maintaining the current requirement of at least four years academic training?
Option 2: Complementing the current requirement of a minimum four-year academic training
by a requirement of two years of professional practice. As an alternative option, architects
would also qualify for automatic recognition after completing a five-year academic
programme, complemented by at least one year of professional practice.
EN 21 EN
4.7. Automatic recognition in the areas of craft, trade and industry
In the areas of craft, trade and industry, automatic recognition is contingent on two
conditions: (1) a certain number of years of experience, which varies according to the activity;
and (2) a clear identification of the professional activity, based on Annex IV of the Directive.
Concerning the first condition, the evaluation has shown that there are no reasons for
changing the minimum number of years of experience required. Concerning the second
condition, there is a strong body of opinion that Annex IV in its current form does not always
allow for clear identification of a profession based on the activities listed therein. At present,
Annex IV refers to International Standard Industrial Classification of All Economic Activities
(ISIC)32
though not in its most recent version, sometimes dating back to the 1950s and 1960s.
One option would be to take as a basis the same ISIC classification but in its most recently
revised form of 2008 which now includes a more precisely defined list of activities. With
rapid technological advances, defining and updating qualifications and corresponding
professions is important. Various stakeholders have also proposed as alternative solutions the
EU common procurement vocabulary33, which is updated on a regular basis, and the
International Standard Classification of Occupations (ISCO) nomenclature34, as revised in
2008.
Whilst a modernised Directive should retain the principle of automatic recognition for the
professions in the areas of craft, trade and industry, the classification of the activities
themselves could be carried out at a later stage, drawing on the results of the study.
Question 23: Which of the following options do you prefer?
Option 1: Immediate modernisation through replacing the ISIC classification of 1958 by the
ISIC classification of 2008?
Option 2: Immediate modernisation through replacing Annex IV by the common vocabulary
used in the area of public procurement?
Option 3: Immediate modernisation through replacing Annex IV by the ISCO nomenclature
as last revised by 2008?
Option 4: Modernisation in two phases: confirming in a modernised Directive that automatic
recognition continues to apply for activities related to crafts, trade and industry activities. The
related activities continue to be as set out in Annex IV until 2014, date by which a new list of
activities should be established by a delegated act. The list of activities should be based on
one of the classifications presented under options 1, 2 or 3.
32 Nomenclature adopted by the United Nations in 1948 and revised in 1958, 1968, 1989 and 2006 (the
latest revision was published in 2008).
33 See Regulation (EC) No 2195/2002 of the European Parliament and of the Council of 5 November 2002
on the Common Procurement Vocabulary (CPV) (OJ L 340, 16.12.2002, p.1) as most recently modified
in 2009. Available at:
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2002:340:0001:0001:EN:PDF
34 Adopted by the International labour Organisation (ILO) and available at:
http://www.ilo.org/public/english/bureau/stat/isco/index.htm
EN 22 EN
4.8. Third country qualifications
The Professional Qualifications Directive, in essence, applies to EU citizens holding
qualifications acquired in an EU Member State. However, it also helps EU citizens holding
qualifications acquired outside the European Union (for instance a diploma from Canada or
China):
The Directive applies to EU citizens who initially acquired qualifications in a third country, if
such qualification has already been recognised in a Member State and the EU citizen
concerned has also acquired three years of professional experience in the above Member
State. Article 3 (3)) facilitates free movement: of such an EU citizen once he or she moves to
another Member State. The EU citizen can therefore benefit from all the procedural
safeguards under the so-called general system (such as a rapid and substantiated decision
whether the qualification can be recognised). In brief, three years' lawful and effective
professional experience in a Member State allows for a treatment of the initial third-country
qualification as if it had been acquired in a Member State.
However, the Directive also contains safeguards to guarantee the minimum training
requirements which are already harmonised at European level (for certain health professions
and architects). According to Article 2 (2) of the Directive, Member States should not accept
third country qualifications from EU citizens if the level of the qualification does not meet the
minimum requirements specified for qualifications acquired in the EU. Member States should
also avoid triggering a brain drain of skilled workforce from non-EUcountries35.
The main question is whether the overall shortage of skilled workforce calls for an adjustment
of the above provisions. Such adjustment would in the first instance benefit EU citizens.
However, it could also have an impact on certain third country nationals who enjoy rights
under European legislation: family members of EU citizens36, long term residents37,
refugees38, and "blue card" holders39 are treated in the same way as EU citizens with respect
to recognition of professional qualifications (although the relevant legislative instruments do
not bind all Member States of the European Union). This adjustment would underpin the
policy of the European Union to also enhance mobility in the context of the revised European
Neighbourhood policy.
Question 24:
Do you consider it necessary to make adjustments to the treatment of EU citizens holding
third country qualifications under the Directive, for example by reducing the three years rule
in Article 3 (3)? Would you welcome such adjustment also for third country nationals,
including those falling under the European Neighbourhood Policy, who benefit from an equal
treatment clause under relevant European legislation? (Please give specific arguments for or
against this approach.)
35 In this context the WHO Global Code of Practice on the International Recruitment of Health Personnel
is to be taken into consideration.
36 Directive 2004/38/EC.
37 Directive 2003/109/EC.
38 Directive 2004/83/EC.
39 Directive 2009/50/EC.
EN 23 EN

Da: x fai da te 21/10/2011 10:06:10
la "professional qualifications" è la 2005/36 non la 98/5

Da: x fai da te 21/10/2011 10:14:44
un minimo di verifica prima almeno no?

Da: iocivogliocredere 21/10/2011 10:18:03
@FAI :
e la madonnnaaaa !!! :
Ma non bastava link che mi si impalla il pc XD ???

Da: :D 21/10/2011 10:18:04
date ancora ascolto a questo personaggio?
ci è rimasto solo OLLLLLE a stargli dietro, difatti è l'unico non iscritto in italia della sua regione, chissà perchè, forse gli serve della pratica in spagna da comprare a peso prima di rassicurarlo nel depositare la domanda in italia.

Da: iocivogliocredere 21/10/2011 10:21:01
@FAI : se ci hai messo un VIRUS e mi prendo il raffreddore ti faccio causa ehh XD ? Traduce in inglese vediamo adesso :)

Da: fai da te originale 21/10/2011 10:26:47
scusate ma che volete di più, questo mi hanno mandato e questo vi posto. C'è scritto "Professional Qualifications Directive", leggete post prima. Ho altri documenti ma a me pare ch questo sia esaustivo.

Da: col cazzo 21/10/2011 10:30:10
invece di scappare dalla verità insultando fai da te, leggete bene! Qui hanno fatto una direttiva che di fatto elimina tutte le precedenti. Ora c'è da capire come regolaranno ogni singola professione. Se fa da te ha questa generale deve avere anche quella sugli avvocati.

Da: infatti 21/10/2011 10:32:14
tocca pure la mobilità temporanea, quindi salta pure la legge 31

Da: Calzino 21/10/2011 10:36:24
per il CCBE va tutto bene così come è stato fino ad ora:

http://www.ccbe.org/fileadmin/user_upload/NTCdocument/03_03_2011_EN_CCBE_r1_1299752250.pdf

Da: Calzino 21/10/2011 10:37:43
non esiste, si è sempre parlato di favorire ulteriormente la mobilità tra i professionisti in ambito europeo.
Qui si torna indietro di 50 anni, a questo punto tanto vale uscire pure dall'euro (che poi non manca così poco)

Da: x fai da te 21/10/2011 10:38:57
ma poi non c'è un voto parlamentare è solo una conferenza e non si tiene il 9 novembre ma il 7 novembre e comunque la direzione intrapresa consiste nell'ampliare non nel limitare le libertà

Da: Calzino 21/10/2011 10:41:54
comunque siamo ancora in una fase embrionale della vicenda, non mi sembra il caso di creare allarmismi:

http://ec.europa.eu/internal_market/qualifications/docs/conferences/20111107-modernisation/agenda20102011_en.pdf

il tutto dovrebbe essere nato da una proposta dello UK, trovandosi nel loro paese medici ed infermieri di paesi europei come polonia, romania etc...con scarso livello di preparazione e zero lingua inglese.
Poiché, ad oggi, la salute è competenza esclusiva di ogni singolo stato, giustamente si vuole riformare il flusso di operatori in tale settore in ambito europeo.

Da: semmai 21/10/2011 10:45:11
la direttiva sarà modificata cioè avverrà in senso a noi favorevole

Da: Calzino 21/10/2011 10:46:30
sembrerebbe operare solo per le professioni a riconoscimento automatico o che cmq non comporta un limbo come i 3 anni di stabilimento nel nostro caso.

leggete, nasce tutto da vicende nel settore medico:

http://www.guardian.co.uk/society/2011/oct/20/rules-on-eu-doctors

http://translate.googleusercontent.com/translate_c?hl=it&rurl=translate.google.com&tl=it&u=http://www.guardian.co.uk/society/2011/oct/19/peers-tougher-rules-eu-medics%3FINTCMP%3DSRCH&usg=ALkJrhjWRKpdPHxrl3YT-6klOYcM_3B0dw

difatti la direttiva in esame NON RIGUARDA L'AVVOCATURA:

http://translate.googleusercontent.com/translate_c?hl=it&rurl=translate.google.com&tl=it&u=http://ec.europa.eu/internal_market/qualifications/policy_developments/legislation_en.htm&usg=ALkJrhgHltoaT1CnwRXFzU4fQgfyWnBG9w#annexes

CIAO FAIDATE, trovane un'altra

Da: fai da te originale 21/10/2011 10:51:45
voglio premettere che, qui ho l'impressione che si tenti di guarire la malattia parlando male del medico. Io mi sto rivolgendo a delle persone laureate in due stati in giurisprudenza o sbaglio? Io con educazione e potendomene fregare alla grande vi sto postando quello che mi hanno mandato. Il dato è tratto, non è nulla di embrionale, a dicembre c'è il voto finale. Non parlo inglese, quindi a mala pena riesco a comprendere il contenuto di quello che vi ho messo a disposizione. O volete dire che ho scritto tutto io, come la comunicazione del cgae !
Da questo momento mi faccio i fatti miei e continuate ad illudervi che tutto va bene.
Se ne volete sapere di più ecco la mail di chi può aiutarvi.
MARKT-PQ-EVALUATION@ec.europa.eu
buoa giornata a tutti

Da: x Calzino 21/10/2011 10:54:43
scusa non per difendere fai da te, ma qui ha ragione. Ohhhhh si parla di direttiva qualifiche. Essere avvocato è una qualifica!!!
Non nascondiamo la testa sotto la sabbia come al solito

Da: mi pare che 21/10/2011 10:57:59
la direttiva riguardi l'avvocatura solo per quanto riguarda il regime generale ma restano salve le disposizioni speciali della direttiva 98/5

Da: Calzino 21/10/2011 11:00:11
grazie "mi pare che", era quello che cercavo di far capire, però forse le cose bisogna dirle espressamente qui.
Noi, come avvocati di paesi europei, abbiamo una normativa ad hoc, che è la direttiva del 98.

qui si parla d'altro, se poi faidate è stato invitato a mangiare tartine a bruxelles, cazzi suoi

Da: x Calzino 21/10/2011 11:01:16
ok, ma non diciamo che non riguarda l'avvocatura. Non dimentichiamo che per un ingegnere siamo qui a bestemmiare tutti i giorni. Qui che significa parte dai medici? Poi, alla fine del voto ciò che uscirà oggi non possiamo saperlo. Però diamo atto a fai da te che ci ha informati, invece di dire cretinate, tipo non riguarda gli avvocati. Poi avemo tempo e modo d legge e tradurre quello che sarà alla fine.

Da: x Calzino 21/10/2011 11:04:48
sei così sicuro che la direttiva 98 rimarrà così com'è? Guarda che quella postata coinvolge tutte le professioni

Da: Calzino 21/10/2011 11:05:59
ma hai letto il contenuto di cosa ho postato, io almeno ho messo i link, non un copia-incolla da chissà quale provenienza.

guarda che con google ci vogliono pochi minuti per informarsi, a meno che uno non sia rimasto alla collazione degli atti con ago e filo, ormai le cazzate reggono il tempo che uno che le legge riesce a fare 2+2

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Da: xfai da te originale	21/10/2011 08:29:04
per caso ti riferisci a: Agnieszka MatuszakEuropean CommissionDG Internal Market and ServicesFree movement of professionals (Unit E4)* European Commission, B-1049 BrusselsOffice: Rue de Spa 2 06/032, 1000 Brussels

Da: Italoabogado = Asino	21/10/2011 08:34:52
Basta ragliare. A studiare!

Da: iocivogliocredere	21/10/2011 09:27:09
Sei sempre qui a controllare interessi che non ti appartengono tu che inviti gli altri allo studio.. ma tu ne hai pratiche di clienti da studiare :) ?

Da: fai da te originale	21/10/2011 09:40:18
x Iocivoglio..... perchè mi hanno invitato non posso certamente postarlo qui. Tu che dici? Diciamo che in passato ho ricoperto qualche carica ...... e non escludo di ricoprirne di nuovo. Mandami una mail in privato ne parliamo come l'ho fatto con chiunque ho visto essere una persona seria ed onesta. Ma di una cosa stai pur certo, la direttiva nuova c'è. Non è che facendo finta di nulla che le cose si risolvono. Qui se chiude la porta pure Roma ........ il titolo di abogado diventa una pezza da muro come quello di odontoiatra rumeno.

Da: wow	21/10/2011 09:52:35
ma che cazzo stai dicendo, ma sai almeno che la direttiva deve poi essere recepita? ci son voluti 3 anni per recepire quella del 98. Ti prego, falla finita che tra te e quello che si firma comme Avv.s. non so chi è peggio!

Da: iocivogliocredere	21/10/2011 09:56:48
Se fossi femmina ti direi : come sono afffffassscinanti questi uomini misteriosi. Essendo maschietto.. ci devo pensare a cosa dirti :). Cmq dimmi tutto ma non dirmi che sei "un certo" PierSilvio (questa non la sopporterei) XD ! ps serio: Anche io ho provato a dare un'occhiata veloce e non l'ho trovata : posti link gentilmente ? Buon lavoro

Da: iocivogliocredere	21/10/2011 09:59:41
ps @ FAI: ma se ti do la mail mi dai il biglietto dell'invito che voglio andare a mangiarli freschi i cavolini XD ?

Da: fai da te originale	21/10/2011 10:01:16
Draft Agenda Public Conference on the Modernisation of the Professional Qualifications Directive Brussels, 7 November 2011 Charlemagne building Rue de la Loi 170 1040 Brussels Belgium 08.00 - 09.00 Registration 09.15 - 09:45 Opening of the Conference - Speech by Commissioner Barnier followed by Questions / Answer session 09:45 - 10:15 Speech by a representative of the Polish Presidency of the Council followed by Questions / Answer session 10.15 - 10.45 Speech by Malcolm Harbour MEP, Chairman of the Internal Market and Consumer Protection Committee of the European Parliament followed by Questions / Answer session 10.45 - 11.00 Coffee Break 11.00 - 12.30 PANEL: Impact of the recent educational reforms on the Professional Qualifications Directive a) Introduction by Paul Harris (to be confirmed), GHK presenting outcome of an independent study b) Further panellists:, Emilie Turunen MEP (Greens, DK), Lesley Wilson (Secretary General of the European University Association), Tillman Prinz (Chief executive, German Federal Chamber of Architects), Robert Rochefort MEP (ALDE, France) (to be confirmed) 12.30 - 13.30 Lunch break 13.30 - 14.45 PANEL: The public health dimension in the Directive Panellists: Bernadette Vergnaud MEP (SD - France), Baroness Young of Hornsey (House of Lords), Giovanni Leonardi (Deputy Director General in Ministry of Health in Italy); Andrzej Rys (Director

Da: x fai da te	21/10/2011 10:06:10
la "professional qualifications" è la 2005/36 non la 98/5

Da: x fai da te	21/10/2011 10:14:44
un minimo di verifica prima almeno no?

Da: iocivogliocredere	21/10/2011 10:18:03
@FAI : e la madonnnaaaa !!! : Ma non bastava link che mi si impalla il pc XD ???

Da: :D	21/10/2011 10:18:04
date ancora ascolto a questo personaggio? ci è rimasto solo OLLLLLE a stargli dietro, difatti è l'unico non iscritto in italia della sua regione, chissà perchè, forse gli serve della pratica in spagna da comprare a peso prima di rassicurarlo nel depositare la domanda in italia.

Da: iocivogliocredere	21/10/2011 10:21:01
@FAI : se ci hai messo un VIRUS e mi prendo il raffreddore ti faccio causa ehh XD ? Traduce in inglese vediamo adesso :)

Da: fai da te originale	21/10/2011 10:26:47
scusate ma che volete di più, questo mi hanno mandato e questo vi posto. C'è scritto "Professional Qualifications Directive", leggete post prima. Ho altri documenti ma a me pare ch questo sia esaustivo.

Da: col cazzo	21/10/2011 10:30:10
invece di scappare dalla verità insultando fai da te, leggete bene! Qui hanno fatto una direttiva che di fatto elimina tutte le precedenti. Ora c'è da capire come regolaranno ogni singola professione. Se fa da te ha questa generale deve avere anche quella sugli avvocati.

Da: infatti	21/10/2011 10:32:14
tocca pure la mobilità temporanea, quindi salta pure la legge 31

Da: Calzino	21/10/2011 10:36:24
per il CCBE va tutto bene così come è stato fino ad ora: http://www.ccbe.org/fileadmin/user_upload/NTCdocument/03_03_2011_EN_CCBE_r1_1299752250.pdf

Da: Calzino	21/10/2011 10:37:43
non esiste, si è sempre parlato di favorire ulteriormente la mobilità tra i professionisti in ambito europeo. Qui si torna indietro di 50 anni, a questo punto tanto vale uscire pure dall'euro (che poi non manca così poco)

Da: x fai da te	21/10/2011 10:38:57
ma poi non c'è un voto parlamentare è solo una conferenza e non si tiene il 9 novembre ma il 7 novembre e comunque la direzione intrapresa consiste nell'ampliare non nel limitare le libertà

Da: Calzino	21/10/2011 10:41:54
comunque siamo ancora in una fase embrionale della vicenda, non mi sembra il caso di creare allarmismi: http://ec.europa.eu/internal_market/qualifications/docs/conferences/20111107-modernisation/agenda20102011_en.pdf il tutto dovrebbe essere nato da una proposta dello UK, trovandosi nel loro paese medici ed infermieri di paesi europei come polonia, romania etc...con scarso livello di preparazione e zero lingua inglese. Poiché, ad oggi, la salute è competenza esclusiva di ogni singolo stato, giustamente si vuole riformare il flusso di operatori in tale settore in ambito europeo.

Da: semmai	21/10/2011 10:45:11
la direttiva sarà modificata cioè avverrà in senso a noi favorevole

Da: Calzino	21/10/2011 10:46:30
sembrerebbe operare solo per le professioni a riconoscimento automatico o che cmq non comporta un limbo come i 3 anni di stabilimento nel nostro caso. leggete, nasce tutto da vicende nel settore medico: http://www.guardian.co.uk/society/2011/oct/20/rules-on-eu-doctors http://translate.googleusercontent.com/translate_c?hl=it&rurl=translate.google.com&tl=it&u=http://www.guardian.co.uk/society/2011/oct/19/peers-tougher-rules-eu-medics%3FINTCMP%3DSRCH&usg=ALkJrhjWRKpdPHxrl3YT-6klOYcM_3B0dw difatti la direttiva in esame NON RIGUARDA L'AVVOCATURA: http://translate.googleusercontent.com/translate_c?hl=it&rurl=translate.google.com&tl=it&u=http://ec.europa.eu/internal_market/qualifications/policy_developments/legislation_en.htm&usg=ALkJrhgHltoaT1CnwRXFzU4fQgfyWnBG9w#annexes CIAO FAIDATE, trovane un'altra

Da: fai da te originale	21/10/2011 10:51:45
voglio premettere che, qui ho l'impressione che si tenti di guarire la malattia parlando male del medico. Io mi sto rivolgendo a delle persone laureate in due stati in giurisprudenza o sbaglio? Io con educazione e potendomene fregare alla grande vi sto postando quello che mi hanno mandato. Il dato è tratto, non è nulla di embrionale, a dicembre c'è il voto finale. Non parlo inglese, quindi a mala pena riesco a comprendere il contenuto di quello che vi ho messo a disposizione. O volete dire che ho scritto tutto io, come la comunicazione del cgae ! Da questo momento mi faccio i fatti miei e continuate ad illudervi che tutto va bene. Se ne volete sapere di più ecco la mail di chi può aiutarvi. MARKT-PQ-EVALUATION@ec.europa.eu buoa giornata a tutti

Da: x Calzino	21/10/2011 10:54:43
scusa non per difendere fai da te, ma qui ha ragione. Ohhhhh si parla di direttiva qualifiche. Essere avvocato è una qualifica!!! Non nascondiamo la testa sotto la sabbia come al solito

Da: mi pare che	21/10/2011 10:57:59
la direttiva riguardi l'avvocatura solo per quanto riguarda il regime generale ma restano salve le disposizioni speciali della direttiva 98/5

Da: Calzino	21/10/2011 11:00:11
grazie "mi pare che", era quello che cercavo di far capire, però forse le cose bisogna dirle espressamente qui. Noi, come avvocati di paesi europei, abbiamo una normativa ad hoc, che è la direttiva del 98. qui si parla d'altro, se poi faidate è stato invitato a mangiare tartine a bruxelles, cazzi suoi

Da: x Calzino	21/10/2011 11:01:16
ok, ma non diciamo che non riguarda l'avvocatura. Non dimentichiamo che per un ingegnere siamo qui a bestemmiare tutti i giorni. Qui che significa parte dai medici? Poi, alla fine del voto ciò che uscirà oggi non possiamo saperlo. Però diamo atto a fai da te che ci ha informati, invece di dire cretinate, tipo non riguarda gli avvocati. Poi avemo tempo e modo d legge e tradurre quello che sarà alla fine.

Da: x Calzino	21/10/2011 11:04:48
sei così sicuro che la direttiva 98 rimarrà così com'è? Guarda che quella postata coinvolge tutte le professioni

Da: Calzino	21/10/2011 11:05:59
ma hai letto il contenuto di cosa ho postato, io almeno ho messo i link, non un copia-incolla da chissà quale provenienza. guarda che con google ci vogliono pochi minuti per informarsi, a meno che uno non sia rimasto alla collazione degli atti con ago e filo, ormai le cazzate reggono il tempo che uno che le legge riesce a fare 2+2