Guidance

Guidance for regulators on the agreement between the United Kingdom and Switzerland on the recognition of professional qualifications (RPQ)

Updated 30 June 2025

Introduction

The agreement between the United Kingdom and Switzerland on the recognition of professional qualifications^{[footnote 1]} establishes a system for the UK and Switzerland to recognise professional qualifications between the 2 countries.

The system came into force in the UK on 1 January 2025.

Regulators of professions covered by the agreement are legally required to operate this system.

This guidance provides information for regulators on the implementing legislation^{[footnote 2]}, and sets out their obligations under the regulations.

This guidance does not include information about the impact of these regulations on individual professions.

For further details not covered within this guidance, you can:

• check profession-specific information provided by the UK government or by the devolved governments

• get in touch with the relevant government departments

This guidance should be read in conjunction with guidance on the recognition of professional qualifications under the UK’s free trade agreement with Norway, Iceland and Liechtenstein^{[footnote 3]}.

Summary

In summary:

• regulators in scope of the regulations are required to have processes in place to recognise comparable qualifications obtained in Switzerland

• regulators outside the scope of the regulations are not required to implement the provisions of the regulations – they are free to establish their own routes to recognition for Swiss qualifications, or apply relevant sectoral legislation or international conventions where applicable

• regulators should continue to uphold recognition decisions made before 1 January 2025 for professionals qualified in Switzerland

Background

The regulations came into force in the UK on 1 January 2025. They implement the recognition of professional qualifications (RPQ) provisions set out in chapter 2 of the agreement. The UK signed the agreement with Switzerland in June 2023.

Chapter 2 outlines a system for recognition of professional qualifications between the UK and Switzerland.

Under the agreement, UK regulators are required to establish or operate routes for recognition of professional qualifications obtained in Switzerland. Annex A of the agreement also sets out additional legal-sector specific provisions for certain legal professionals.

The agreement is reciprocal, so regulators in Switzerland are also required to recognise UK qualifications.

These arrangements replace the RPQ provisions that were contained in the agreement between the United Kingdom and Switzerland on Citizens’ Rights (the CRA), which expired on 31 December 2024. The CRA contained provisions on RPQ and applied to UK and Swiss nationals, whereas this agreement applies to professional qualifications from Switzerland and the UK regardless of the professional’s nationality^{[footnote 4]}.

The regulations

The regulations:

• place a duty on UK regulators to establish or operate a system for recognition of comparable professional qualifications obtained in Switzerland

• give regulators the powers to recognise these qualifications by making amendments to sectoral legislation where necessary

Similar provisions on RPQ in chapter 12 of the Free Trade Agreement between the UK and Iceland, Norway and Liechtenstein (EEA EFTA FTA) came into force on 1 December 2023: the Recognition of Professional Qualifications and Implementation of International Recognition Agreements (Amendment) Regulations 2023 (EEA EFTA Regulations). Due to similarities between the 2 RPQ arrangements, the regulations amend the EEA EFTA regulations, adding Switzerland as a specified state in schedule 1 of the EEA EFTA regulations and extending the legal requirements on UK regulators. Where there are differences between the 2 agreements, the regulations amend the EEA EFTA regulations.

For some professions, sector specific legislation regarding the previous EU-based system applies in parallel to these regulations. For example, the European Qualifications (Health and Social Care Professions) (Amendment etc.) (EU Exit) Regulations (2019/593) (the standstill provisions). In such cases, this legislation may create additional requirements for regulators to implement beyond what is required in the regulations.

Regulators should consult their relevant department to understand what additional requirements may apply to them.

Scope

Professions in scope of the regulations

The regulations apply to professions regulated by law in the UK, whether at a national, regional or local level, unless specifically excluded in the regulations.

For a profession to be considered in scope of the agreement, a person who seeks to practise a profession must be required by law to hold qualifications to practise that profession or use a professional title.

Professions outside the scope of the regulations

Professions which are subject to industry-led regulation, such as some chartered professions, are not in scope of the regulations and are not required to have processes in place to recognise comparable qualifications obtained in Switzerland. However, they may choose to recognise Swiss qualifications in line with the terms of the agreement.

The regulations do not apply to the regulators of certain maritime, aviation and dangerous goods professions. A full list of these professions is included in regulation 13 of the regulations. These professions are subject to existing international agreements on recognition of professional qualifications.

Application in devolved nations

The regulations apply across all UK nations where the profession is regulated centrally by the UK government. The regulations apply in Scotland and Northern Ireland for professions that are regulated at a devolved level.

The Recognition of Professional Qualifications and Implementation of International Recognition Agreements (Amendment) (Extension to Switzerland and Miscellaneous Provisions) (Wales) Regulations 2024 apply to professions within Welsh Government competence.

Regulators of professions that are matters of devolved competence should engage with the appropriate government to ensure they are compliant with the relevant regulations.

Recognition under new system

Regulators will need to ensure that they are able to process applicants with professional qualifications or relevant experience gained in Switzerland:

• in a fair and proportionate manner

• in line with the requirements and powers set out in the regulations

In summary, the regulations require regulators to:

• recognise qualifications or relevant experience of a professional who applies for recognition and possesses comparable professional qualifications

• refuse applications of comparable qualifications only when one or more conditions specified in the regulations are met (detailed later in this guidance)

• apply certain compensatory measures to address differences in qualifications in certain circumstances

• follow specific procedural requirements outlined in the regulations

The specific procedural requirements include:

• following certain steps within specified time periods

• ensuring any evidence requirements are no more than necessary and exchanging information with Swiss regulators

• publishing and making easily available information that is relevant to applicants applying for recognition

• operating a fair and proportionate system for language requirements, appealing decisions and application fees

If access to a regulated profession in the UK relies on a person holding specific professional qualifications, regulators must recognise qualifications obtained in Switzerland that are comparable to professional qualifications obtained in the UK.

It is for the regulator to assess how qualifications from Switzerland relate to a UK qualification and whether they are comparable. This assessment of comparability is dependent on each regulated profession’s needs and requirements.

It is up to individual regulators to set their approach for comparability and make decisions based on this.

Should a regulator judge that a qualification is not comparable, then the requirements of the regulations would not apply. In this case, regulators can decide what procedures such applicants can follow, in line with relevant legal requirements and public law principles (such as proportionality and accountability).

Refusal to recognise qualifications

When considering an application to recognise comparable professional qualifications obtained in Switzerland, regulators may decide to refuse to recognise a professional qualification when one or more of the following conditions in article 2.4 of the agreement are met:

Condition 1

Condition 1 has 2 parts that need to be met for a regulator to refuse to recognise a professional qualification where both:

• a substantial difference between the professional qualification and the essential knowledge or skills required to practise the profession in the UK exists

• the applicant fails or refuses to take an aptitude test or complete an adaptation period (compensatory measures)

Condition 2

Condition 2 has 2 parts that need to be met for a regulator to refuse to recognise a professional qualification where both:

• regulators consider that the regulated profession in the UK has one or more professional activities that cover substantially different matters from those covered by the Swiss professional’s qualifications

• the professional fails or refuses to take an aptitude test or complete an adaptation period (compensatory measures)

Condition 3

Requiring the professional with a Swiss qualification to take an aptitude test or to complete an adaptation period would amount to requiring the professional to acquire the relevant qualification in the UK.

Condition 4

Article 2.6 also provides that a regulator can refuse recognition of a professional qualification where both:

• access to and pursuit of a profession in the UK by those who gained their professional qualifications in the UK is subject to conditions other than the possession of specific qualifications

• the professional fails to meet those conditions

Regulators can also request Swiss qualified professionals provide evidence of compliance where access to a regulated profession by UK professionals is subject to conditions other than the possession of specific professional qualifications, for example:

• ethics

• proof of good character

• possession of insurance

Compensatory measures

A compensatory measure is an adaptation period or aptitude test.

An adaptation period is a period of supervised practice during which a professional may be assessed or receive further training.

An aptitude test is a test of a professional’s knowledge specific to the profession, with the aim of assessing the professional’s ability to pursue that profession in the UK.

Except for the bespoke system for legal services regulators outlined below, a regulator can require a professional to undertake one or both of these measures to address differences between the qualification obtained in Switzerland and the equivalent UK qualification.

Annex A of the agreement offers a bespoke recognition route to certain legal services professionals. Legal services regulators are required to provide applicants with a choice between the adaptation period or the aptitude test.

Regulators should offer applicants such compensatory measures when there are substantial differences, as described in conditions 1 and 2, before deciding to refuse an application.

Regulators are encouraged to apply compensatory measures in a proportionate manner to the differences they seek to address. If requested by the professional, regulators should explain in writing why they have requested that the applicant undertake compensatory measures.

Where a regulator requires an applicant to undertake an aptitude test, the regulator must schedule tests:

• with reasonable frequency

• at least once a year

Procedure for applications

Timeframe obligations

Regulators must have processes in place that enable them to meet the following requirements when processing applications from professionals who hold professional qualifications from Switzerland:

• acknowledge receipt of the professional’s application within one month of receipt and inform the professional of any missing documents

• grant the professional adequate time to complete the requirements and procedures of the application process

• deal promptly with the professional’s application

• issue a decision no later than 4 months after the date on which the complete application was submitted

Evidence requirements

Regulators may request evidence from applicants who hold a professional qualification gained in Switzerland.

This may be evidence of the qualification the professional holds or evidence to demonstrate that they satisfy certain conditions other than the possession of specific professional qualifications.

Where such evidence is required, regulators must:

• ensure the evidence is not more than is necessary to demonstrate that the professional holds comparable professional qualifications, or satisfies the conditions

• accept copies of documents authenticated in accordance with UK law in place of originals, unless original documents are required to protect the integrity of the recognition process

• collaborate and exchange information with regulators in Switzerland to help the processing of an application (where applicable)

• exchange information on disciplinary action taken, criminal sanctions imposed or any other serious, specific circumstances which are likely to have consequences for a person to practise the profession in the UK (where applicable, and subject to confidentiality requirements)

Regulators must comply with UK data protection law when exchanging information with regulators in Switzerland.

Other provisions

Regulators must also provide information to professionals holding Swiss qualifications about the:

• relevant UK laws to be applied, for example on disciplinary action, financial responsibility or liability

• principles of discipline and enforcement of professional standards (including disciplinary jurisdiction and any consequential effects on practising professional activities)

• process and procedures for the ongoing verification of competence

• criteria for, and procedures relating to, revocation of registration

• documentation required of professionals, and the form in which it should be provided

• acceptance of documents and certificates issued in relation to professional qualifications and other conditions required to practise the profession

Regulators must deal promptly with enquiries from professionals about the qualification and other conditions required to practise the profession.

It is up to the discretion of regulators to decide how they satisfy this requirement. Examples of satisfying this request could be putting the above up-to-date information on:

• the Regulated Professions Register

• their website

Language requirements

Regulators may choose to require minimum language proficiency of professionals qualified in Switzerland. If regulators choose to do so, language tests must be proportionate to the requirements of the profession.

Appeals

Regulators must provide a right of appeal to professionals with qualifications obtained in Switzerland against their:

• decision to refuse access to and pursuit of a profession

• failure to make a decision about a professional’s access to and pursuit of a profession

While regulators have a degree of discretion as to what their appeals process should look like to be compliant with the regulations, they should ensure that their appeal processes are compatible with the applicable legal frameworks and public law principles that apply to them.

Fees

Regulators can charge fees to process applications to recognise qualifications obtained in Switzerland. These fees must be:

• reasonable and proportionate to the cost of the application

• transparent in relation to fee structures and made public in advance

• payable by electronic means

Additional provisions for certain legal professions

Annex A of the agreement sets out a bespoke route to recognition for certain legal professionals. These professionals are subject to the same obligations contained in the Agreement, in addition to these additional provisions.

A lawyer qualified in the UK or Switzerland can register with the host authority in the other party, provide legal services in that country under their home title for 3 years. Subject to meeting the other conditions (as set out previously), they can requalify into the legal profession of the opposite country.

The Annex covers the UK legal regulators responsible for the professions of advocate, barrister or solicitor. These professionals are referred to as ‘covered lawyers’ in the Agreement.

Article A.3 places a duty on the regulators of these legal professionals to offer the choice between:

• completing a 3-year period of supervised practice, called an ‘adaptation period’

• taking an aptitude test in order to apply for requalification into the legal profession of the opposite country

If the covered lawyer chooses to complete an adaptation period, the Agreement then provides detail on what an adaptation period is and how it works. Generally, the adaptation period is 3 years’ effective and regular practice of the law of the host jurisdiction under home title.

The regulator must also register the lawyer (but can refuse, subject to a right of appeal). The regulator may prevent the lawyer undertaking certain professional activities and must apply the same rules of professional conduct as apply to professionals holding the legal title of the host jurisdiction.

Article A.4 sets out that on recognition, the legal regulator must permit the covered lawyer to also use the legal title for which they are responsible.

Recognition of Swiss professional qualifications before 1 January 2025

Recognition decisions made before 1 January 2025 for professionals who qualified in Switzerland remain valid. 

If regulators received an application before 1 January 2025 from a professional who qualified in Switzerland, they should continue to consider that application using previous processes.

Should a professional who qualified in Switzerland and who previously practised in the UK (but not on 1 January 2025), apply to rejoin the profession in the UK, the regulator can refer to its rules as to whether the professional needs to make a new full application for recognition. Should the regulator decide that the previous decision is not applicable and the professional therefore needs to apply again for recognition , the regulator should follow the process set out in the regulations. 

Regulators should refer to guidance  on applications made before 1 January 2025.

Other requirements for regulators to comply with

Regulators should ensure that information about recognition routes for professionals qualified in Switzerland is updated on their profession pages on the Regulated Professions Register. This information is important for professionals seeking to practise in the UK to be able to apply according to the correct process.

Section 8 of the Professional Qualifications Act 2022 places a duty on regulators of professions regulated by law to publish information about requirements to practise.

Sections 9 and 10 of the Professional Qualifications Act 2022 place a duty on regulators of professions regulated by law to share information with a regulator in another part of the UK or a regulator overseas when requested to do so by the professional. Regulators should refer to guidance  on these requirements if needed.

Contact

For further information contact recognitionarrangements@businessandtrade.gov.uk.

Annex 1: sector-specific arrangements

Exclusion of certain maritime, aviation and dangerous goods professions

The regulations do not apply to regulators of professions listed in Schedule 2 of the EEA EFTA Regulations. Regulators, as amended by the regulations, of these professions do not need to comply with the regulations, with respect to the listed professions.

The professions listed are certain aviation, maritime and dangerous goods professions subject to existing multilateral international arrangements.

Aviation professions

The EEA EFTA States and Switzerland have entered into an agreement with the EU to participate in the European Union Aviation Safety Agency (EASA) system. This is by virtue of Article 129 of Regulation (EU) 2018/1139 (the EASA Basic Regulation) which requires the application of EU aviation safety legislation, including requirements on personnel licensing.

Aviation professionals are also subject to arrangements under the Convention on International Civil Aviation (Chicago Convention). Therefore:

• Switzerland cannot independently enter into agreements with third countries on the recognition of licences and qualifications which come within the scope of the EU aviation safety legislative framework

• UK regulators of aviation professions cannot recognise Swiss aviation qualifications under the terms of the RPQ Agreement

Maritime professions

The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (the STCW) already covers RPQ arrangements for maritime professions between the UK and Switzerland. Regulators of maritime professions should continue to recognise professional qualifications in Switzerland in accordance with the terms of the STCW.

Dangerous goods driving professions

The European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) and the Regulations concerning the International Carriage of Dangerous Goods by Rail (RID) already covers RPQ arrangements for these professions between the UK and Switzerland and are incorporated into domestic legislation. Regulators should recognise qualifications obtained in Switzerland in accordance with terms of the ADR and RID.

Amendments modifications or additional provisions relevant to legal services legislation

The regulations amend, modify or supplement sectoral legislation for the purpose of or in connection with implementing the RPQ agreement. In particular, part 4 of the regulations make modifications and amendments in respect of sectoral legislation relating to legal services professions in England and Wales to ensure that the relevant regulators have the necessary powers to implement the Swiss RPQ Agreement, including the provisions of Annex A.

Amendments in relation to anaesthesia associates and physician associates (AAPA)

The AAPA Order 2024 came into force on 13 December 2024. This order means that the professions of anaesthesia associates (AA) and physician associates (PA) fall within the scope EEA EFTA Regulations. The AA and PA provisions in the regulations came into force on 19 December 2024, earlier than the other provisions in the regulations, so that they could comply with RPQ provisions of the EEA EFTA FTA.

1. The agreement between the United Kingdom and Switzerland on the recognition of professional qualifications ↩

2. The Recognition of Professional Qualifications and Implementation of International Recognition Agreements (Amendment) (Extension to Switzerland etc.) Regulations 2024 ↩

3. Available from Professional Qualifications Act 2022: guidance for regulators ↩

4. The CRA’s RPQ provisions apply to Swiss nationals and certain third country nationals with an enforceable EU right to be treated no less favourably than a national of either state, whereas the UK-Switzerland RPQ Agreement applies to professional qualifications from that country (regardless of the professional’s nationality) ↩