ACCA welcomes the opportunity to respond to the European Commission’s public consultation on the Skills Portability Initiative. We reaffirm our support for the EC’s Union of Skills strategy and efforts to facilitate labour mobility. ACCA similarly supports the intent of the three action areas. These broadly cover digitalisation, enhanced recognition processes, and simplified rules for recognising third-country nationals’ qualifications. As a truly global accountancy body, we see alignment with ACCA’s own global policy priorities. That includes ‘Bridging the accountancy skills gap’, so that businesses can access the right skills to thrive.

The accounting profession has a vital role to play in advancing the European Union’s (EU) green and digital transitions. This includes supporting accountants and businesses understanding of the Omnibus Directive Package and AI Act obligations. ACCA’s calls highlighting the importance of clarity and consistency similarly relate to EU Directives relevant to recognition of professional qualifications. The EC’s intent to advance harmonisation comes at a pivotal juncture, especially with the pipeline of qualified professionals inadequate to meet the demands of both. This is illustrated in the EC’s own research into the declining number of statutory auditors; likewise, ACCA’s Global Economic Conditions Survey (GECS). The GECs Employment Index dropped again for Western Europe in Q4 2025, approaching pandemic-era lows.^[1]

The dearth of talent is compounded by barriers hindering cross-border mobility. While restrictions to professional access play their part, the main barrier is the diversity of Member State’s legal and regulatory frameworks. Professional accountants seeking to practice in another Member State must demonstrate sufficient knowledge of local requirements and ensure they serve the public interest. ACCA holds that professional qualifications obtained in one Member State should be recognised across all EU countries. Alongside responses to specific questions, ACCA makes the following recommendations:

Recommendations

1. Harmonisation with International Federation of Accountants (IFAC) International Education Standards (IESs): ACCA advocates use of global frameworks that support international alignment and interoperability. EU alignment with IFAC International Education Standards can boost cross border recognition of qualifications.
2. Digitise qualification recognition across member states: Recognition processes should be simplified and digitalised where possible. Alleviate fragmentation by investing in digital tools like EQF and Europass, integrating results of both into a single, transparent platform.
3. Centralised EU Information Portal: Develop a multilingual, centralised EU portal with clear, step-by-step guidance for professionals, students, and employers. A multi-lingual portal can positively contribute to an agreed upon taxonomy. Information on key areas, such as compensation measures, should be reliable and continuously updated.
4. Promote fair mobility and inclusive labour markets: ACCA recommends expansion and alignment of stay-back regimes across Member States, using Ireland’s model to retain international graduates and support local economies.
5. Integrate visa and qualification applications to facilitate access to talent: A unified system can bring greater predictability and improve the EU’s attractiveness globally as a place to work.
6. Cross border mobility must be accompanied by appropriate safeguards: Provision of services in another Member State should only occur with appropriate certification from the country of origin and Professional Accounting Organisations (PAO). Cross-border mobility should only be facilitated where such competency is demonstrated.
7. Promote fair mobility and inclusive labour markets: ACCA support efforts that encourage greater alignment between National Qualifications Frameworks (NQFs) and the European Qualifications Framework (EQF); likewise, the benefits of regularly updating the former. Ireland’s model, including its stay back regime, serves as a model of how alignment can help retain international graduates and support local economies.

[1] ACCA policy and insights, Global Economic Conditions Survey: Q4 2025, p.6, available here.

To read the response in full, please download the consultation document found on this page.