ACCA believes that the existing Professional Qualifications Directive (PQD), coupled with the European Qualification Framework (EQF), is well aligned with ACCA’s mission to provide opportunity and mobility to its students and members.
Karen Yates, head of education for Europe at ACCA says: 'Both the PQD and the EQF have been successful in helping the mobility of professionals within Europe and also globally, including professionally qualified accountants, by providing a system of recognition that has been particularly useful for individuals and competent authorities. Mobility across national frontiers is key to ACCA’s objectives, one of which is to offer high quality professional accountancy qualifications not only in Europe, but globally.'
ACCA nevertheless shares the views of the European Parliament in its response to the European Commission's Green Paper on the modernisation of the Professional Qualifications Directive that cross-border mobility for professionals can be improved.
ACCA believes the recognition of qualifications should be accelerated, though not at the expense of the reliability and security of EU citizens. ACCA specifically supports the idea put forward of a voluntary professional card that would list the professional qualifications obtained by the cardholder. To make the most of it, it should be linked to the Internal Market Information (IMI) system and be matched with necessary safeguards.
Karen Yates adds: 'The general idea of a voluntary European professional card for easing recognition procedures and increasing cross-border mobility as well as transparency and trust, is attractive.
'Whereas the Directive on Statutory Audit is clearer on recognition for auditors and for the provision of an aptitude test, there has been difficulty under the general system to identify which competent authority to contact especially when going from an unregulated to a regulated profession.
'A card, exploiting modern technologies that ensures reliability and security, could help overcome this obstacle. Engineers have introduced a card and advocate its usefulness so this is a solid example of how it could work for other professions.'
It is useful to consider the impact of existing European initiatives in the field of education on how qualifications are obtained and defined. ACCA is in favour of using learning outcomes to align the Professional Qualification Directive with EQF levels, and putting more emphasis on the continuing professional development.
ACCA also shares the European Commission’s view that the number of regulated professions, as long as the latter do not have public safety implications, should be reduced.
On the other hand, proposals such as partial access and common platforms require a level of complexity and consideration especially as far as their implementation is concerned, and risk creating a more burdensome solution, hence bringing more obstacles than they solve.
Karen Yates continues: 'ACCA agrees with the partial access principle as a more effective means to identify common areas of minimum training requirements than common platforms. In the case of the latter, they may work for a small number of professions to possibly increase automatic recognition beyond the current seven ones, but it would not work for the accountancy profession where national tax and law would be outside the scope of any platform or harmonisation.
'Any form of top down or exclusive approach that would include a small minority of member states or competent authorities would not be acceptable in the spirit of the Directive.'
ACCA is more concerned about the full implementation of the Statutory Audit Directive in all member states, as it already provides the equivalent of a common platform for auditors. Similarly the IFAC International Education Standards for Professional Accountants (IFAC IES) provides a satisfactory common benchmark in the field of accountancy services - which are regulated in certain EU member states but not in others.
Karen Yates points out: 'We consider the Statutory Audit Directive and the IFAC IES to both provide a common ground, by which the quality of qualifications already obtained can be assessed, and also solid backstop measures against ‘qualifications shopping’. We therefore view any extra benchmarks – such as excessively detailed or exclusive platforms - to be unnecessary and, in so far as they are exclusive, would further impede the free movement of auditors and professional accountants across the borders of member states.
'We need to be realistic about how simplistic the recognition of professional qualifications could and should be, and take into account the aspects of consumer protection and trust.'