1. Although none of the countries surveyed has yet developed a Credit Accumulation and Transfer system that possesses all the characteristic to which UK proponents of CAT tend to aspire, the higher education systems of several countries embody many of them. These include: student choice (Sweden), pacing of studies (NL, D, E, S), discrete course units (NL, E, S), movement between modes of study (S) and transfer between institutions (all sample countries). In fact, one of these characteristics: the freedom of students to pace their studies has caused much concern in countries such as the Netherlands, Sweden and Germany because of the increasing time being taken by students to qualify. Action to resolve this problem is being taken in the Netherlands and Sweden (which both now have systems explicitly based on credit). Financial pressures are being applied to students (NL) or to institutions (S) to curtail the duration of study.

2. Even in German Universities where studies are not credit-based there is a long tradition of student transfer and mobility. In 1995 the HRK (Council of German university rectors) indicated that about 25 per cent of German university students studied at more than one institution.

3. The 1993 reforms of higher education in Sweden which established general degrees were intended to give students more choice in constructing their programmes of study, allowing students either to specialise or to create multidisciplinary programmes.

4. Institutions in the UK and the 5 sample countries have participated in the European Commission’s pilot project to develop the European Credit Transfer System (ECTS). This project, started in 1989, operated within the former Erasmus programme. By 1995 it had come to involve 400 institutions in 17 countries which used the system to permit their students to undertake part of their studies in at least one other country. Funds to encourage other European universities to introduce ECTS are available under the Socrates programme and last year 1100 institutions applied for support to undertake preparation activities to use ECTS.

5. The system focuses on the development and use of three key documents to create transparency: an information package in a relatively standardised format describing the institution, its courses and academic practices; a learning contract negotiated between home and host institution and the mobile student; and, a transcript of records (to effect the transfer of credits).

6. ECTS is not, however, a European qualifications framework: it involves no definition of ‘levels’; no specification of how many ECTS credits are necessary for an award (that depends on the awarding body); no specification of how many hours of student workload equal one ECTS credit. No-one has the authority to make such specifications (Article 126 and 127 of Treaty on European Union). Nevertheless, ECTS has been, and is, one of the Commission’s most powerful tools to tackle the problems of recognition. It encourages institutions to attempt to describe their programmes in a common language (credits) and to confront some of the real issues that block recognition (these undoubtedly include concerns about standards and quality best illustrated, perhaps, by the difficulty of attempting to transfer grades, or marks, in addition to simple credits).

7. The European Commission speaks of creating a European qualifications area. It considers that the mutual recognition of academic and vocational qualifications could be developed through the adoption of a system for the transfer of teaching credits. Experience from the ECTS project and its extension, however, would suggest that there is much to do before that could be achieved. The Commission, however, does not intend to make any further directives to Member States in this area because of the need to respect the principle of subsidiarity. It observed in a recent publication that:

‘All member states are in favour of improving mobility in principle, but their actions are do not always correspond to declared intentions. This is particularly true ... when it comes to education and training, (as) whenever a single brick is touched, the whole building can be affected’.

(Le Magazine for Education, Training and Youth in Europe, issue 6, p5, 1996, The European Commission, Brussels).