1. The five European countries in the survey are members of the European Union, the OECD, the Council of Europe and UNESCO. The UK, too, is a member of all except UNESCO, where it has observer status. These organisations all have an interest in education and training and have variously, according to their powers, issued conventions and directives or instigated transnational co-operation programmes and projects. They have done this with the aim of facilitating comparisons between national higher education systems and/or securing the recognition of qualifications. None has the power to intervene directly in national systems of higher education and qualifications.

2. An important obstacle to the international recognition of qualifications is a lack of information and understanding of other nations’ education systems and qualifications. This, and the variety of national systems of education and training in the European Union, has resulted in a number of unsuccessful attempts to achieve a common terminology and comparability of qualifications. The concept of subsidiarity has also, to some extent, hampered recognition of qualifications in the EU. Over the last few years the debate over recognition has moved from defining international equivalences to the acceptance of qualifications from other Member States.

National and bilateral activities

3. Although national authorities produce publications on their higher education systems and statements about the value of their national academic awards, this does not in itself secure international recognition. The provision of information can be helpful, but real recognition only comes when individuals achieve recognition in other countries for their qualifications.

4. Within Europe, there are examples of bi-lateral agreements at national level for the mutual recognition of academic qualifications, such as that between Germany and France, which recognises the Diplom and maîtrise for admission to doctoral studies in both countries. The UK has no such bi-lateral agreements, which may be because its academic qualifications are not national awards, as in other European countries, but are granted by individual institutions. Evidence suggests, however, that should the UK seek such agreements, many Western European countries would not be willing to equate the UK bachelor’s degree (with the possible exception of Scottish awards) with their own graduate awards. The following quotation makes this clear:

‘Information .. .indicates that it is safe to say that the (doctoraal) degrees [which result in the title of doctorandus] granted by Dutch universities are on a par ... with the English Master’s degree, the French maîtrise and the German Diplom. The Dutch bachelor’s degree (granted by Hogescholen) finds its counterpart in the non-university types of higher education such as the German Fachhochschulen, and is often accepted as equivalent to American and British bachelor’s degrees.’

(Higher Education in the Netherlands, Nuffic, 1994 p50).

This contrasts with the view of the UK Naric, British Council, in its International Guide to Qualifications in Education, 1996 (Fourth Edition) p578:

Doctoraal: generally considered comparable to British bachelor (Honours) degree standard although the course lasts longer than in the UK. ... HBO diploma : a professionally-oriented first degree: generally considered to be comparable to a standard above that of BTEC Higher national Diploma/N/SVQ level 4. Some institutions compare it to a UK first degree, some others require a minimum 65%. In some circumstances it may be considered for admission to a taught Master’s degree course.

5. One reason for the, not uncommon, Dutch view quoted above, is that a three-year UK degree is shorter and thus considered less substantial than other European degrees. Also, the fact that UK degrees are not required to include a thesis, or dissertation, might be taken to indicate that a UK degree is less academically demanding. In the past this has been countered by the argument that the UK has a highly selective admission procedure for university entrance, that UK students are already ahead of their continental counterparts on entering higher education because of the specialisation of GCE-A level, and that UK Honours degrees frequently require a special project. The grounds for these arguments have become less secure with the expansion of UK higher education, its more heterogeneous intake, the wider spread of A levels studied by individual students, the growth of modular degrees and the introduction of longer courses in certain science and technology subjects.

De facto recognition of UK degrees in Europe

6. The UK has attracted numerous students from other European states, both through EU student exchange programmes and individual entry. There are also many examples of joint degrees (a single UK award studied in a UK institution and another country) and of double degree programmes (those which lead both to a UK degree and a qualification in another country). These merit closer scrutiny to establish whether they enhance perceptions of the standards of UK higher education and qualifications. Many of the joint programmes which have been established are with non-university institutions in Germany, France and the Netherlands. In others, the non-UK qualification is not a nationally recognised award and so is not directly equivalent value to a UK degree. Surveys of visiting students’ experiences in UK higher education, within the former Erasmus programme, indicated that they valued the quality of their higher education experience in the UK but also revealed that they did not find the academic demands too heavy, or even as heavy as at home. (Ulrich Teichler, Experiences of Erasmus Students: select findings of the 1988/89 survey, ERASMUS Monographs No 13, 1991). There is also some evidence that UK undergraduate students have difficulty in participating in such student exchange programmes. Although this is generally attributed to linguistic weaknesses, it seems more often to reflect a mismatch in certain subject areas (for example, Engineering) in the content, teaching style and level of courses between the UK and continental partner institutions.

European Union - laws and actions in relation to recognition of qualifications

7. The freedom of movement of labour and the freedom of establishment for the self-employed are fundamental EU objectives. In both cases the basic principle is that of equality of treatment for all EU-national citizens. The requirements of Member States concerning the training of employed and self-employed people may create obstacles to the achievement of these objectives. Many of these requirements may not be discriminatory in themselves. They may, however, impede the free movement of people because they differ from country to country, and frequently oblige the individual to take further training and to sit examinations to comply with local requirements. Article 57 of the Treaty on European Union empowers the Council of Ministers to issue directives for the mutual recognition of diplomas, certificates and other evidence of formal qualifications, and for the co-ordination of national provision concerning the taking up and pursuit of activities as self-employed persons.

8. Until relatively recently, very little progress had been made in the field of mutual recognition of diplomas. From the mid-1970s the, then, European Community attempted some exercises in the comparability of qualifications. Advisory committees on training were set up and a series of directives were issued. Their aim was to facilitate the mutual recognition of diplomas, certificates and other evidence of formal qualifications in order to promote the freedoms to establish a business and to provide services in any Member State. These directives include EU-wide comparability of qualifications for doctors (1975 and 1993), nurses (1977), dental practitioners (1978), veterinarians (1978), midwives (1980), architects (1985) and dispensing chemists (1985). These are commonly referred to as the sectoral directives. In parallel, the Council, in July 1985, decided to lay down provisions relating to the comparability of vocational training qualifications in the hotel and restaurant, motor vehicle repair and construction sectors.

9. These comparability exercises were time-consuming and arduous and, by the late 1980s, there was a move away from the notion of comparability to one of mutual recognition. A general system for the recognition of higher education diplomas awarded on completion of professional education and training of at least three years’ duration was adopted by the Council in 1988. EEC89/48 is the diploma directive the salient features of which are:

  • the principle of mutual trust between member states;
  • the principle of the comparability of university studies between member states;
  • the mutual recognition of diplomas without prior harmonisation of the conditions for taking up and pursuing occupations; and
  • the principle that any divergence between Member States, in particular as regards training, will be offset by vocational experience.

Thus, providing those wishing to exercise a profession fulfil certain minimum conditions as to their qualifications, experience and professional education, their qualifications will be recognised in all Member States and they will be authorised to pursue their activities without restriction.

10. A similar system covers diplomas and certificates awarded on completion of professional education and training in higher education of less than three years’ duration, or not undertaken through higher education. This embraces two levels of training: higher education and post-secondary diplomas completed in under three years; and secondary education diplomas. It also applies to certain non-graduates with acquired professional experience. Provision is made to link the two systems in order to include professions which fall under the first system in one member state and under the second in another. In instances where significant differences in the duration of the training and education exist, or where there are substantial differences in the content of the training and education acquired, the host member state may seek proof of vocational experience, or require individuals to take a competence test or additional adaptation training.

11. The two general systems for the recognition of diplomas ensure that any EU national has the right to have vocational qualifications obtained in one member state recognised in another. It is important to note that these directives apply only to ‘regulated professions’ and that it is incumbent upon each state to specify what it considers to fall into this category. There are great differences from one state to another in the professions regulated under EEC 89/48, as can be seen for example by comparing the lists issued by the UK and Sweden.

12. Each member state has a contact point (National Co-ordinator) for citizens seeking advice about the directives and/or support for their case for recognition. The UK National Co-ordinator for EEC/89/48 is the Department of Trade and Industry (DTI), the co-ordinator’s role concerns mobility of labour and right of establishment issues. The UK National Co-ordinator for EEC/92/51 (an extension of EEC/89/48) is a part of the DfEE. National Co-ordinators meet in Brussels about four times a year to discuss issues relating to the implementation of the directives.

13. The meetings of National Co-ordinators have become a focus for the disquiet in Spain, Germany and Greece concerning the cross-border franchising of UK qualifications, particularly when these have been offered on completion of programmes of study in unregulated, commercial organisations. Some member states are refusing, or have threatened to refuse, to recognise these UK-franchised qualifications and claim that, even in the case of regulated professions, the directives do not apply to these awards. While the tacit reason for this may be the desire for state sovereignty over higher education, much of the criticism has focused on concerns about the quality and standards of franchised provision. There are allegations that a principle of the directive, the comparability of university studies, is being breached by some of these courses.

14. The debate, which has been proceeding for the last 18 months, may only be resolved when a citizen takes a case to the European Court of Justice. Commission officials have indicated that cross-border franchising of higher education is an activity protected by Articles 52, 57 and 60 of the Treaty. The directive might, however, be considered only to apply to awards where the franchised course or programme of study is identical to the programme in the UK. This is clearly not the case in many courses franchised to Greece and Spain which may be taught and examined in the local language; in which curricula and examinations may have been changed to reflect local culture and needs; and where, sometimes, no equivalent award exists in the UK-franchising institution. It should also be noted that a number of UK professional bodies are becoming concerned about the implications of cross-border franchising. Some have issued advice to UK universities on the requirements necessary to protect the accreditation and status of awards in the UK.

15. In 1975, the Council set up the European Centre for the Development of Vocational Training (CEDEFOP), subsequently located in Thessaloniki. CEDEFOP’s work focuses on two priority areas: qualification and vocational training systems. The work on qualification concerns the transparency of qualifications at a European level and that on training systems the development of strategies and the dissemination of information on the optimum combinations for all types of training.

16. The mutual recognition of diplomas and other evidence of formal qualifications is linked to freedom of establishment and vocational training. Both education and training are included in the provisions of the Maastricht Treaty on European Union. EU action in these areas should, however, respect the responsibility of member states for the content and organisation of their educational and vocational training systems, and their cultural and linguistic diversity.

17. Article 126 states that the Community may contribute to the development of quality in education by encouraging co-operation between member states and by supporting and supplementing their action in the fields of:

  • the teaching and dissemination of languages;
  • the mobility of students and teachers;
  • co-operation between educational establishments;
  • the exchange of information and experience; and
  • the development of distance education.

In the area of education, the Commission has power to propose incentive measures. The current major Community action in education is the Socrates programme which comprises measures and projects intended to promote transnational co-operation. At the national level, support for National Academic Recognition Information Centres (Narics) to undertake projects and issue publications on academic recognition and qualifications is available through the Socrates programme. At Community level, current Socrates activities include the recognition of qualifications and the establishment of a joint EU-Council of Europe-UNESCO Working party to consider the development of a diploma supplement – a transcript of records – which might be issued to individuals to aid the recognition of qualifications for academic and professional purposes.

18. Under Article 127 of the Maastricht Treaty, Member states agreed to implement a vocational training policy that supports and supplements the action of individual states and which aims to:

  • facilitate adaptation to industrial changes, in particular through vocational training and retraining;
  • improve initial and continuing vocational training in order to facilitate vocational integration and re-integration into the labour market;
  • facilitate access to vocational training and encourage mobility of instructors and trainees;
  • stimulate co-operation between educational and training establishments and firms; and
  • develop exchanges of information and experience on issues common to the training systems of the member states.

19. The EU also runs the Leonardo programme that is designed to promote and support quality and innovation in the field of training. It has four main objectives:

  • support for the improvement of Member States’ vocational training systems and arrangements;
  • support for the improvement of vocational training actions, including university-industry co-operation for the benefit of companies and employees;
  • support for the development of language skills, knowledge and the dissemination of innovation; and
  • to take complementary measures in areas such as information and monitoring.