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Recognition after a No-Deal Brexit

The Withdrawal Agreement negotiated between the British government and the EU, including the transition period, will only come into force if it is ratified by the European and British parliaments.

On 28 October 2019 the British government and the EU agreed to postpone the deadline for withdrawal of the United Kingdom – Great Britain and Northern Ireland (in the following: United Kingdom) – from the EU to 31 January 2020. If there is no majority for the Withdrawal Agreement until then, there will be a “disorderly“ exit. This is referred to as no-deal Brexit in the following.

In this case, EU law in regards to the United Kingdom would, according to the present state of affairs, no longer be applicable after 31 January 2020. The United Kingdom would thus become a third country from Germany’s perspective.

Please note

Please note

The parliamentary process in the United Kingdom is still ongoing. You can read the latest updates on the German Government’s website  at the link below.

What would a No-Deal Brexit mean for the recognition of professional qualifications from the United Kingdom in Germany?

Will the recognition of my professional qualification still be valid?

If your professional qualification obtained in the United Kingdom has already been recognised in Germany, the recognition will remain valid, even after a no-deal Brexit.

I already obtained my professional qualification in the United Kingdom before the exit, but I have not yet submitted an application for recognition. Can I have my qualification recognised in Germany even after a no-deal Brexit?

You can still submit an application for recognition in Germany. British nationals can also still have their professional qualifications recognised in Germany. The recognition depends on the relevant national law in the country concerned. You can request more information about this from the competent authorities, who you can search for using our Recognition Finder.

I submitted an application for recognition until 31 January 2020 but I have not received an answer yet.

If you submitted the application in Germany until 31 January 2020, the decision should be made according to the legal stipulations valid at the time of application as long as this is legally (i.e. pursuant to the relevant specific legislation) possible. The competent authority for recognition can provide you with more information about this.

I will have only completed my professional qualification in the UK after 31 January 2020. Can I still submit an application for recognition in Germany?

Yes, you can submit an application for recognition. However, the EU Directive on the recognition of professional qualifications will no longer be applicable. In its place, the recognition system for professional qualifications from third countries will be applicable.

Please note

Please note

In the event of a no-deal Brexit, the regulations concerning cross-border service provision (freedom to provide services) and the EU freedom of movement will no longer apply to British nationals after the exit date.

Legal basis

In Germany, everyone has the right to a recognition procedure—regardless of nationality and origin of the professional qualification. This is based on the Recognition Act from 2012. This means that, even after a no-deal Brexit, British professional qualifications can still be recognised in Germany.

What will change after a No Deal Brexit, however, is the legal foundation for the recognition of certain professional qualifications. Until Brexit, the EU Recognition Directive 2005/36/EG for regulated professions is applicable to British professional qualifications. A simplified method of automatic recognition for certain professions is provided for in this directive. It cannot be applied to qualifications that are obtained in the UK after Brexit. During the recognition procedure in Germany, an individual equivalence assessment for all British professional qualifications takes place.