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The Professional Qualifications Bill [HL] 2021-22 was announced in the Queen’s Speech on 11 May 2021 and first introduced in the House of Lords. Consideration of the Bill by the House of Commons started on 18 November 2021.

This briefing provides background to the Bill, summarises the Lords stages, and the Commons proceedings up to the sitting of the Public Bill Committee on 18 January 2022.

What does the Bill do?

The Bill would set out a new system for how professional qualifications gained abroad are recognised in the UK. It would also seek to allow regulators in the UK and overseas to mutually recognise qualifications where they cannot do that now.

In the UK, more than 200 professions are regulated by law. UK regulators of professions such as nursing, architecture, or veterinary, have established certain processes to recognise credentials gained overseas.

These rules help determine whether qualifications acquired abroad include an adequate level of skill and training for the professionals to practice in the UK, and sometimes whether they can use a professional title. The UK’s current system to recognise professional qualifications comes from EU law.

A new system

The Government intends to create a new system which would mean that regardless of where the qualifications have been gained, they have to meet the same requirements to be recognised in the UK. The current system inherently treats qualifications gained in the EU and EEA countries, Norway, Iceland, and Liechtenstein differently.

The Bill would create powers to allow regulators of professions in the UK to enter into ‘regulator recognition agreements’ with their international counterparts. The Government states this will “strengthen the UK’s ability to negotiate and deliver ambitious [trade] deals”, where they relate to professional qualifications, and help UK professionals enter new markets abroad.

The regulation of some professions, including teaching, is devolved. The Bill provides for the cooperation of regulators across the four nations of the UK by creating a new system for information sharing. It also establishes an Assistance Centre for individuals who seek to practice in the UK or abroad.

Finally, the Bill amends the Architects Act 1997, creating a new recognition system for architects.


The first reactions to the Bill were mixed. Several regulators, including the Architects Registration Board, the Nursing and Midwifery Council, and the Law Society generally welcomed the Bill and the possibilities it would open to work with international partners.

Regulators of healthcare professions raised concerns about the Bill’s potential to allow professional standards to be “watered down”, with implications for patient safety. Some Members of the House of Lords  questioned whether the Bill was even necessary.

Changes in the Lords

To address regulator concerns, the Lords have accepted government amendments and have added two new clauses to the original Bill:

  • to protect the autonomy of regulators, and
  • to require that regulators are consulted before new regulations are made in areas of their existing powers.

Devolved aspects

The Government is seeking legislative consent for aspects of the Bill that fall within devolved areas. On recommendation of the respective governments, Senedd Cymru and the Scottish Parliament are withholding their consent and calling for further amendments to the Bill. The decision of the Northern Ireland Assembly is pending in absence of a fully functioning Northern Ireland Executive. Discussions between the UK Government and the devolved administrations continue.

Commons stages

At second reading and in committee, MPs debated regulator autonomy and the need for further assurances to devolved administrations about the protection of the areas of devolved competence.

Other issues included the Bill’s contribution to addressing workforce shortages, and government support to regulators negotiating mutual recognition agreements under the UK and EU Trade and Cooperation Agreement (TCA).

The Public Bill Committee did not significantly amend the Bill.

An issue expected to return at the report stage is the duty for the Government to consult with or secure the consent of devolved administrations before making regulations in areas of devolved responsibility.

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