Cleared in One Country.
Three More to Check.

68,000 Unfilled teaching positions in Germany by 2035
50-65% Recognition applications requiring compensation measures
4-12 wk Per country for ECRIS criminal record checks
C1-C2 Language proficiency required for state school deployment
VETTING ARCHITECTURE

The Check Your Agency Can't Run.

Education safeguarding requires country-specific checks that go beyond standard criminal record disclosure. In France, the decisive check is employer-access only — no agency can run it independently. In Germany, the wrong criminal record certificate misses the convictions that matter. Standard agencies consistently check the wrong things, or only one country.

UK United Kingdom
2-6 weeks
Standard Agency
✓ Enhanced DBS
What Teaching Requires
✓
Enhanced DBS
✗
TRA Prohibition Check Teaching Regulation Agency — separate system. Checks whether the individual is prohibited from teaching by the Secretary of State. Routinely omitted.
✗
Children's Barred List Issued by DBS but requires explicit request. Confirms the individual is not barred from regulated activity with children.
DE Germany
4-8 weeks
Standard Agency
✓ Standard Führungszeugnis
What Teaching Requires
✗
Erweitertes Führungszeugnis §30a BZRG Extended certificate of good conduct. Covers juvenile criminal records and all child-relevant convictions hidden from the standard certificate. §30a-specific — not issued by default.
FR France
4-12 weeks
Standard Agency
✓ Bulletin No. 2 du Casier Judiciaire
What Teaching Requires
✓
Bulletin No. 2 du Casier Judiciaire
✗
FIJAIS — Fichier Judiciaire Automatisé des Infractions Sexuelles National sex offender and violent offender register. Mandatory for all teaching roles in France.
Employer Only
Employer Access Only — No Agency Can Run This Check

No agency can run this check independently. FIJAIS requires direct employer coordination with the French Ministry of Justice (Direction des Affaires Criminelles et des Grâces). Any provider claiming to deliver complete French safeguarding checks without this channel has a structural gap — not a procedural one. The check does not exist in their process.

NL Netherlands
2-4 weeks
Standard Agency
✓ Generic VOG (no profile specification)
What Teaching Requires
✗
VOG Profile 84 — Sexual Integrity Must be requested by profile number. Screens for sexual offences. A generic VOG does not screen this category.
✗
VOG Profile 85 — Working with Minors Covers convictions relevant to working with children. Mandatory for teaching. Requires renewal every 3 years. Issued by Justis.
ECRIS Coordination

When a candidate has resided in multiple countries, BSS initiates vetting in all jurisdictions simultaneously — not sequentially. Each country requires apostilled documentation and sworn translations. Processing time per country: 4-12 weeks. A teacher with residence history across three countries: three concurrent vetting tracks, initiated on programme day one.

SECTOR COVERAGE

Five Sub-Sectors. One Compliance Framework.

Primary Education Early years through primary, aged 4-11. State, independent, and international primary schools.
Complex Recognition Secondary — STEM Mathematics, sciences, engineering, technology. Shortage subject across all four markets.
Secondary — Humanities History, geography, modern languages, English literature, social sciences, aged 11-18.
Complex Recognition Special Educational Needs SEND teaching, SEMH, autism spectrum, communication and interaction needs, EHC plan delivery.
Further Education & VET Post-16 vocational training, apprenticeship delivery, adult skills, VET programmes.
Roles
Primary TeacherEarly Years PractitionerTeaching AssistantSENCO (Primary)

Primary teaching qualifications are assessed under the general system — no automatic recognition. Competent authority in each host country assesses against its own early-years and primary curriculum framework. Compensation measures required in 45-60% of applications. Language requirement at C1 minimum: all teacher-pupil and teacher-parent communication must be conducted in the host-country language. A teacher unable to communicate a safeguarding concern clearly is a safeguarding risk, not merely a language-barrier case.

Compliance Standards
Directive 2005/36/EC general systemEnhanced DBS + TRA + Barred ListCEFR C1 minimumHost-country curriculum framework assessment
Complex qualification recognition pathway. Compensation measures in 60-80% of applications. Language assessment at C1-C2 subject-specific level. Adaptation period typically required.
Roles
Mathematics TeacherPhysics TeacherChemistry TeacherComputer Science Teacher

STEM qualifications face the highest recognition complexity. Subject-combination differences between national curricula mean substantial differences are identified in 60-75% of applications. A Physics Staatsexamen from Germany assessed against French CAPES Physique-Chimie faces specific subject-scope, pedagogical tradition, and assessment-method differences. Fachsprachprüfung (Germany): subject-specific language at academic expert level — separate from, and additional to, general language certification.

Compliance Standards
Directive 2005/36/EC general systemSubject-specific substantial differences assessmentFachsprachprüfung (DE)C1-C2 + subject-register vocabulary
Roles
History TeacherMFL TeacherGeography TeacherEnglish Literature Teacher

Humanities qualifications face substantial differences assessment primarily around curriculum scope and pedagogical tradition. Language teachers carry an additional dimension: teaching a foreign language requires demonstrated C1-C2 in the host-country language for classroom instruction PLUS near-native proficiency in the taught language. A Spanish MFL teacher deploying to Germany needs C1 German for classroom management and near-native Spanish for subject delivery — two simultaneous language assessments.

Compliance Standards
Directive 2005/36/EC general systemCurriculum content equivalency assessmentC1-C2 host-country languageCAPES / Agrégation equivalency (FR)
Complex qualification recognition pathway. Compensation measures in 60-80% of applications. Language assessment at C1-C2 subject-specific level. Adaptation period typically required.
Roles
SEND TeacherSEMH SpecialistCommunication & Interaction LeadEducational Psychologist

SEN/SEND carries the most complex safeguarding overlay in education. Practitioners working with pupils who are also subject to adult social care involvement may trigger both the Children's Barred List AND the Adults' Barred List. Qualification recognition for SEND specialisms: UK NASENCo, German Sonderpädagogik, French CAPA-SH, Dutch SEN endorsements each define scope differently — compensation measures in 65-80% of applications. Language requirement is not reduced: SEND communication requires precisely unambiguous language. A misunderstood instruction in a non-verbal or emotionally dysregulated context has direct safeguarding consequences.

Compliance Standards
Enhanced safeguarding + dual barred list (children + adults)SEND-specific qualification recognitionVulnerable adult regulation overlapHost-country SEND legislative framework
Roles
FE LecturerVocational TrainerAssessorSkills Coach

Further education and vocational qualifications use the European Qualifications Framework (EQF) as a reference — EQF provides comparison, not recognition rights. Host-country VET bodies (BIBB/IHK in DE, DIRECCTE in FR, SBB in NL) assess foreign VET qualifications against national standards. Safeguarding obligations are identical to school-based teaching where learners include those under 18. Language requirement varies by subject and delivery mode — safety-critical communication in vocational workshop contexts must be unambiguous at any level.

Compliance Standards
EQF reference framework (not automatic recognition)Host-country VET authority assessmentNQF level equivalency mappingB2-C1 language range by subject
WORKFORCE PROFILES

Five Roles. Distinct Compliance Chains.

COMPLIANCE PROFILE Directive 2005/36/EC general system — no Annex V pathway

Individual assessment in every country. Compensation measures in 45-60% of applications. C1 language is a safeguarding requirement, not an administrative one.

Qualification Recognition General system assessment by host-country competent authority: KMK per Bundesland (DE), MENJS (FR), DUO (NL), TRA (UK). Application includes degree, transcripts, course syllabi, and practicum documentation. Processing: 3-8 months. Compensation measures in approximately 50% of applications — aptitude test or 3-9 month supervised adaptation period.
Safeguarding Vetting Enhanced DBS + TRA Prohibition Check (UK); Erweitertes Führungszeugnis §30a (DE); Bulletin No. 2 + FIJAIS via employer MoJ coordination (FR); VOG Profile 84/85 (NL). Multi-country coordination for any candidate with prior residence in more than one country. 4-12 weeks per jurisdiction. Initiated in parallel from programme day one.
Language Assessment C1 minimum across all four markets. Academic register, classroom management language, safeguarding communication, and parent consultation fluency are all assessed separately. The C1 requirement is not about vocabulary breadth — it is about whether the teacher can communicate an emergency without ambiguity. That is a safeguarding threshold, not a language preference.
Compensation Measures Aptitude test: pedagogical knowledge and curriculum understanding, assessed in the host-country language — language proficiency and subject competency tested simultaneously. Adaptation period: 3-9 months supervised teaching in a host-country primary school. Assessed by a designated mentor and the competent authority. BSS coordinates preparation for both pathways.
Red Flags Enhanced DBS alone presented as complete UK safeguarding. TRA prohibition check omitted. Generic VOG accepted without profile 84/85 specification. FIJAIS not mentioned for French deployment. Recognition letter from home country presented as sufficient for host country. General language certificate accepted without assessment of child-facing communication register.
BSS Assessment Classroom management language scenario: issuing instructions under noise, managing disruption, emergency communication protocol in target language. Parent consultation simulation. Safeguarding disclosure scenario: appropriate language for receiving and reporting a disclosure from a child. Subject-register vocabulary check against destination-country primary curriculum.
COMPLIANCE PROFILE Directive 2005/36/EC general system — subject-specific substantial differences

Highest qualification recognition complexity in education. Compensation measures in 60-75% of applications. Fachsprachprüfung is a separate assessment from general language certification.

Qualification Recognition Subject-specific assessment: competent authority evaluates the qualification against the national curriculum for that subject. German Physik Staatsexamen assessed against French CAPES Physique-Chimie reveals differences in subject scope, laboratory competency standards, and assessment traditions. Compensation measures: aptitude test most common for STEM — tests subject-specific pedagogy and curriculum knowledge at host-country standard.
Safeguarding Vetting Standard education safeguarding vetting applies: Enhanced DBS + TRA (UK), Erweitertes §30a (DE), Bulletin No. 2 + FIJAIS (FR), VOG 84/85 (NL). Subject specialism does not alter the vetting requirement. STEM shortage status does not create an exemption or accelerated vetting pathway — every candidate goes through the same checks.
Language Assessment Two-layer assessment for German deployment: (1) General academic language at C1 minimum. (2) Fachsprachprüfung — subject-specific vocabulary at expert level, separate examination. A candidate with Goethe C1 still requires a separate subject-language assessment for German STEM deployment. Physics, chemistry, and mathematics have distinct Fachsprache that differs materially from general academic German.
Compensation Measures Aptitude test preferred by most competent authorities for STEM — tests subject knowledge depth directly. Test covers: curriculum knowledge in the subject area, pedagogical methodology, assessment design, and differentiation strategies for the age range. BSS provides subject-specific preparation aligned with the competent authority's published examination criteria per jurisdiction.
Red Flags Fachsprachprüfung not identified or mentioned for German deployment. STEM qualification presented as equivalent without subject-scope comparison. Compensation measure not anticipated in programme timeline. General C1 certificate accepted without separate subject-register check. Agency timeline of 3 months for STEM deployment to Germany or France — structurally impossible.
BSS Assessment Subject lesson explanation in target language: candidate explains a core curriculum topic (e.g., quadratic equations, electron configuration) in academically accurate target-language prose. Assessment design exercise: candidate constructs an examination question in the target-language curriculum tradition. Subject vocabulary comprehension tested against destination-country standard textbook register.
COMPLIANCE PROFILE Enhanced safeguarding — dual barred list — SEND-specific recognition pathway

Most complex safeguarding overlay in education. Dual-regulation (children's + adults') may apply. Language failure in SEND contexts is a direct safeguarding risk, not a competency gap.

Qualification Recognition SEND specialisms have the least standardised recognition pathway across the four markets. UK NASENCo, German Sonderpädagogik, French CAPA-SH, and Dutch SEN endorsements each define scope differently. Compensation measures in 65-80% of applications — adaptation period almost universally required because SEND competency is practice-based, not knowledge-based. Adaptation placement must be in a designated SEND provision, not a mainstream school.
Safeguarding Vetting Enhanced standard education vetting applies. Additional consideration: SEND practitioners working with pupils also subject to adult social care may trigger both the Children's Barred List AND the Adults' Barred List (UK) or equivalent dual-register check. Where dual-regulation applies — typically pupils over 16 with continuing SEND provision — both lists must be confirmed. Agencies consistently fail to identify this scenario.
Language Assessment Language requirement is not reduced for SEND contexts — it is more demanding. SEND communication requires: unambiguous language for emotionally dysregulated or non-verbal pupils; clear instructions processable under cognitive or sensory differences; safeguarding communication with precise language when reporting disclosures from pupils who communicate atypically. C1 minimum. No exceptions for SEND contexts. An agency accepting B2 for SEND deployment does not understand what is at stake.
Compensation Measures Adaptation period: 6-12 months typical for SEND specialism. Must be supervised in a designated SEND provision — not a mainstream school. The supervising institution must hold the relevant SEND designation in the host country. BSS sources SEND-specific adaptation placements in each target jurisdiction. Where aptitude test is an option, BSS prepares candidates against the specific SEND competency framework assessed by the host-country authority.
Red Flags Dual-regulation (children's + adults') scenario not identified. SEND qualification presented as equivalent to general teaching without gap analysis. Language bar reduced below C1 on the incorrect assumption that communication is simpler with SEND pupils. Adaptation period placement arranged in mainstream school rather than designated SEND provision. NASENCo treated as equivalent to Sonderpädagogik without a documented equivalency assessment.
BSS Assessment Safeguarding disclosure scenario: candidate receives a non-verbal communication from a pupil indicating a potential concern — assessed response protocol in target language and cultural context. Communication differentiation: how would the candidate adapt their language for a pupil with SEMH needs vs. ASD vs. a non-verbal pupil, in target-language context. Dual-regulation awareness verified. Emergency communication under simulated high-arousal scenario.
COMPLIANCE PROFILE IB / Cambridge IGCSE — school-specific requirements — safeguarding obligations identical

International school status does not create a safeguarding exemption. ECRIS multi-country vetting applies regardless of school sector. FIJAIS requirement is not removed by private school status.

Qualification Recognition International schools (IB, Cambridge, American curriculum) typically set their own qualification requirements rather than following state-school recognition frameworks. A teacher with QTS, PGCE, or equivalent may be deployed without formal host-country recognition. However: this does not remove safeguarding vetting obligations, does not remove language requirements for non-English-medium schools, and does not remove host-country employment law compliance (A1 certificate, posting notification, social security coordination).
Safeguarding Vetting Identical to state-school teaching: Enhanced DBS + TRA (UK candidates/UK schools); Erweitertes §30a (DE residence history); Bulletin No. 2 + FIJAIS (FR residence history); VOG 84/85 (NL residence history). International school status creates no safeguarding exemption whatsoever. FIJAIS: employer must coordinate through official Ministry of Justice channel regardless of school type. ECRIS multi-country coordination required for any candidate with multi-country residence history.
Language Assessment English-medium international schools: English at effective native-equivalent standard for all teacher-facing roles. Non-English-medium international schools (French lycées, Deutsche Auslandsschulen): C1-C2 in the language of instruction required. Mixed-language environments require bilingual competency assessment. Professional communication with parents and administration in the host-country language assessed additionally for non-English-medium environments.
Compensation Measures Where host-country recognition is pursued for career progression, permanent residency, or future state-school access: general system applies identically to state-school route. International school employment does not accelerate or simplify the recognition process. BSS advises on whether recognition pursuit serves the long-term programme objective and manages the process where warranted.
Red Flags Agency advising that international school deployment requires no safeguarding vetting — incorrect without qualification. FIJAIS omitted because the school is private — irrelevant to vetting obligation. Multi-country ECRIS coordination not initiated because the school handles its own DBS — school's internal system may not coordinate ECRIS for other countries of residence. Salary processed locally without A1 certificate — social security liability in both countries.
BSS Assessment Cross-cultural communication assessment: candidate adapts communication style for multilingual parent base and multi-national pupil cohort typical of international school environment. Safeguarding protocol verification: does the candidate understand that the host-country safeguarding authority has jurisdiction regardless of school curriculum? Professional register assessed across English and host-country language where applicable.
COMPLIANCE PROFILE EQF reference framework — host-country VET authority — B2-C1 language range

EQF level is a reference, not a recognition. Safeguarding obligations apply wherever learners under 18 are present. Safety-critical language in vocational delivery is a life-safety requirement.

Qualification Recognition European Qualifications Framework (EQF) provides reference levels 1-8 but does not create recognition rights — it facilitates comparison. VET qualifications are assessed by the host-country VET authority: BIBB and IHK (DE); DIRECCTE and Pôle Emploi (FR); SBB and COLO (NL); Ofsted-regulated providers and AoC framework (UK). Occupational specificity matters: a construction VET qualification has a different recognition pathway from digital technologies or healthcare.
Safeguarding Vetting Full education safeguarding vetting applies for any VET role involving learners under 18. Where programmes include apprentices or school-age participants: Enhanced DBS + TRA (UK), §30a (DE), Bulletin No. 2 + FIJAIS (FR), VOG 84/85 (NL). For adult-learner-only programmes (18+): children's barred list not required, but criminal record disclosure is still mandatory. FIJAIS applies wherever any learner under 18 is included in the programme, including apprenticeships with school-age components.
Language Assessment VET delivery language assessed against the occupational register — a construction trades lecturer needs construction vocabulary, not academic prose. B2 minimum for most VET contexts. C1 required for VET programmes with academic progression components. Safety communication is critical: a misunderstood safety instruction in a workshop environment has direct physical consequences. Safety-register vocabulary must be demonstrably accurate, not approximately correct.
Compensation Measures VET compensation measures tend toward adaptation periods rather than aptitude tests — VET competency is practice-demonstrated. Adaptation period: typically 3-6 months in a host-country VET provider, assessed by workplace mentor. Where recent industry practice is current, the adaptation period may be shortened. BSS maps prior industry experience against host-country VET qualification requirements to identify the shortest compliant pathway per jurisdiction.
Red Flags EQF level equivalency presented as recognition — EQF is a reference tool, not a recognition mechanism. Safeguarding vetting reduced below full standard because learners are described as "mostly adults." FIJAIS not checked because the programme is labelled VET rather than teaching. Occupational qualification recognised at a different sector than deployment (generic NVQ accepted for specialist healthcare VET delivery).
BSS Assessment Technical instruction delivery in target language: candidate explains a core occupational procedure in VET register. Safety communication scenario: candidate issues an emergency stop instruction in workshop context — assessed for clarity, precision, and appropriateness under simulated stress. Assessment feedback exercise: written developmental feedback to a learner portfolio submission at appropriate register and language level.
JURISDICTION INTELLIGENCE

Regulatory Exposure by Market.

Hover any country for full vetting, recognition, and language obligations. Full regulatory mapping provided during technical scoping.

DE Germany Erweitertes Führungszeugnis §30a BZRG: 4-8 weeks. Apostille required. Sworn translation required for non-German documentation.
Regulatory Body KMK (Kultusministerkonferenz), ZAB, 16 Bundesland education authorities
Language C1 minimum for state schools. C2 for Beamtung in Bayern. Fachsprachprüfung (subject language examination) separate from and additional to general language certification.
Vetting Erweitertes Führungszeugnis §30a BZRG: 4-8 weeks. Apostille required. Sworn translation required for non-German documentation.
Risk Level HIGH

Germany operates 16 separate competent authorities — one per Bundesland — with no federal harmonisation. Compensation measures required in 55-70% of applications. Staatsexamen (first + second state examination) is a two-stage qualification with no direct equivalent in most other countries. SOKA-Bau does not apply to teachers but A1 certificate is required. Deutsche Auslandsschulen operate under separate BVA framework. Critical gap: Standard Führungszeugnis consistently ordered instead of the extended §30a variant — the standard certificate omits juvenile records and child-specific convictions.

FR France Bulletin No. 2 (Casier Judiciaire National) + FIJAIS via employer MoJ coordination: combined 4-12 weeks. SIPSI posting notification required.
Regulatory Body MENJS (Ministère de l'Éducation Nationale), CAPPEI commission
Language DELF/DALF C1 minimum. DALF C2 for Agrégation-level posts. Academic and subject-specific register assessed during adaptation period.
Vetting Bulletin No. 2 (Casier Judiciaire National) + FIJAIS via employer MoJ coordination: combined 4-12 weeks. SIPSI posting notification required.
Risk Level HIGH

CAPES and Agrégation are the reference qualifications for secondary state teaching. Compensation measures in majority of applications. FIJAIS is the critical structural gap: no third-party agency can access it — requires direct employer coordination with DACG (Ministry of Justice). Bulletin No. 3 (which agencies sometimes use) is less complete than the mandatory Bulletin No. 2. Private schools (contrat simple/association) operate under a somewhat lighter regulatory framework but safeguarding obligations are identical.

NL Netherlands VOG profile 84/85: 2-4 weeks online via Justis. Renewal required every 3 years for continuous employment. Must specify profile numbers — generic VOG is insufficient.
Regulatory Body DUO (Dienst Uitvoering Onderwijs), SBB, Onderwijsinspectie
Language NT2-II Staatsexamen (C1 Dutch). Arbowet requires demonstrable comprehension of safety instructions in Dutch. Academic and professional register assessed.
Vetting VOG profile 84/85: 2-4 weeks online via Justis. Renewal required every 3 years for continuous employment. Must specify profile numbers — generic VOG is insufficient.
Risk Level MEDIUM

Dutch teaching qualification recognition: WPO framework for primary (Pabo), WVO for secondary (Lerarenopleiding). DUO assesses foreign qualifications. Compensation measures in approximately 50% of cases. Onderwijsinspectie monitors safeguarding compliance at institutional level. VOG must specify profiles 84 AND 85 explicitly — a generic VOG does not capture child-specific offence categories. A1 certificate required. WOR notification for posting.

UK United Kingdom Enhanced DBS + TRA Prohibition Check + Children's Barred List: combined 2-6 weeks. Cannot begin before employment offer confirmed. All three checks are distinct — Enhanced DBS alone is incomplete.
Regulatory Body TRA (Teaching Regulation Agency), DfE, OfSTED, UKVI
Language Effective native-equivalent English required. IELTS Academic 7.5+ or OET Grade B for Skilled Worker visa route. Safeguarding communication assessed as a separate professional standard.
Vetting Enhanced DBS + TRA Prohibition Check + Children's Barred List: combined 2-6 weeks. Cannot begin before employment offer confirmed. All three checks are distinct — Enhanced DBS alone is incomplete.
Risk Level HIGH

QTS (Qualified Teacher Status) mandatory for maintained schools. Post-Brexit: EU qualifications no longer automatically recognised — individual TRA assessment required. Skilled Worker visa: IELTS Academic 7.5+ or approved equivalent. TRA prohibition check routinely omitted by agencies — it is a separate system from Enhanced DBS. International Qualified Teacher Status (iQTS) pathway for overseas deployment. Independent schools: QTS not mandatory but all safeguarding obligations identical. NSI Act 2021 has implications for certain education roles with government adjacency.

COMPLIANCE GRID

Framework Coverage.

Safeguarding & Criminal Record Vetting Country-specific disclosure systems and child protection registers
ECRIS 2009/316/JHA
ECRIS 2009/316/JHA European Criminal Records Information System decision — framework for exchange of criminal record information between EU Member States. Enables multi-country coordination of disclosure checks for internationally mobile workers. Requires separate application per country of residence.
Children Act 1989/2004 (UK)
Children Act 1989/2004 (UK) Primary legislative framework for child safeguarding in England and Wales. Working Together to Safeguard Children statutory guidance. Underpins the Enhanced DBS + TRA + Children's Barred List requirement. All three checks are mandated — Enhanced DBS alone does not satisfy the statutory standard.
BZRG §30a (DE)
BZRG §30a (DE) Bundeszentralregistergesetz §30a — statutory basis for the Erweitertes Führungszeugnis. Mandates disclosure of child-relevant convictions that are excluded from the standard Führungszeugnis. Agencies consistently order the standard certificate; §30a specifies the extended variant.
FIJAIS / Loi 2004-204 (FR)
FIJAIS / Loi 2004-204 (FR) Fichier Judiciaire Automatisé des Infractions Sexuelles — French national sex offender and violent offender register. Created under Loi Perben II. Mandatory consultation for all education roles. Access restricted to employers via Ministry of Justice channel (DACG). Not accessible to third-party agencies.
Wet Justitiële Gegevens (NL)
Wet Justitiële Gegevens (NL) Statutory basis for the Dutch VOG (Verklaring Omtrent het Gedrag). Profiles 84 and 85 specify education-sector screening criteria. Generic VOG does not satisfy the child-specific screening standard — both profiles must be explicitly requested by number.
Keeping Children Safe (UK)
Keeping Children Safe (UK) UK statutory guidance under the Children Act — mandatory for all schools, colleges, and VET providers. Specifies Enhanced DBS + TRA prohibition check + Barred List as the complete required check. Not optional. Not replaceable by a single check. Updated annually.
Qualification Recognition Framework Directive 2005/36/EC general system — teaching is excluded from Annex V
Directive 2005/36/EC
Directive 2005/36/EC Professional Qualifications Directive — primary EU framework for qualification recognition. Annex V provides automatic recognition for medicine, nursing, pharmacy, architecture, dentistry, and veterinary medicine. Teaching qualifications are explicitly excluded from Annex V and fall under the general system (Articles 10-14).
Articles 10-14 (General System)
Articles 10-14 (General System) General system pathway under Directive 2005/36/EC. Requires individual assessment by the host-country competent authority. Permits compensation measures (aptitude test or adaptation period) where substantial differences are identified. Processing time: 3-8 months per jurisdiction. Compensation measures required in 50-65% of teaching qualification applications.
ENIC-NARIC Network
ENIC-NARIC Network European Network of National Information Centres on Academic Recognition — provides equivalency information for qualifications from non-EU countries. Advisory only — does not issue recognition decisions. BSS uses ENIC-NARIC for preliminary gap assessment; formal recognition requires the competent authority application.
KMK Equivalency (DE)
KMK Equivalency (DE) Kultusministerkonferenz framework for assessment of foreign teaching qualifications. No federal authority — 16 Bundesland authorities each conduct independent assessment. Compensation measures set by the relevant Bundesland, not a central standard. Staatsexamen equivalency assessment is the most complex variant.
QTS / iQTS (UK)
QTS / iQTS (UK) Qualified Teacher Status — mandatory for maintained school teaching in England. Post-Brexit, EU qualifications assessed individually by TRA. International Qualified Teacher Status (iQTS) for overseas-trained teachers. Automatic mutual recognition no longer applies for EU-qualified teachers post-January 2021.
EQF / NQF Mapping
EQF / NQF Mapping European Qualifications Framework — 8-level reference framework for comparing qualifications across countries. Does not create recognition rights. Provides initial equivalency mapping. Formal VET qualification recognition requires the full host-country VET authority application regardless of EQF level alignment.
Language, Posting & Deployment Obligations Language certification standards and cross-border deployment compliance
CEFR (Council of Europe)
CEFR (Council of Europe) Common European Framework of Reference for Languages — A1 through C2. State school teaching requires C1 minimum across DE, FR, NL, and UK. C2 required for Beamtung in Bayern. B2 is not sufficient for state school teaching in any of the four principal markets. Language assessment must include subject-specific register, not general conversational competency only.
TestDaF / Goethe C1 (DE)
TestDaF / Goethe C1 (DE) Goethe-Institut Zertifikat C1 or TestDaF 4 in all four sub-tests accepted for German teaching roles. Plus Fachsprachprüfung for subject-specific language at academic expert register. DSH accepted for university-preparatory contexts. C2 (Goethe C2 or TestDaF 5) required for Beamtung in Bayern.
DELF / DALF (FR)
DELF / DALF (FR) Diplôme d'Études en Langue Française and Diplôme Approfondi de Langue Française — issued by CIEP. DALF C1 minimum for teaching roles. DALF C2 for Agrégation-level and advanced professional contexts. Subject-specific vocabulary assessed separately during recognition adaptation period.
NT2-II Staatsexamen (NL)
NT2-II Staatsexamen (NL) Nederlands als Tweede Taal second-level state examination — CEFR C1 equivalent. Required for professional roles in Dutch education. Tests academic writing, reading, listening, and speaking in professional contexts. Issued by DUO. Renewal not required but recency of certification noted by competent authority.
PWD 2018/957
PWD 2018/957 Posted Workers Directive — posted workers receive the same core conditions as local workers including minimum salary, working hours, and leave. Posting notification mandatory: SIPSI (FR), A-Meldesystem (DE), MeldLoket (NL). Penalty exposure up to €500k in some jurisdictions for non-notification.
A1 Certificate / Reg 883/2004
A1 Certificate / Reg 883/2004 Social security coordination certificate confirming home-country social security applies during cross-border assignment. Must be obtained before deployment begins. Retroactive social security liability in both home and host countries results from non-compliance. Required for all cross-border teaching assignments without exception.

Mobilisation patterns in adjacent sectors

Adjacent sectors

Workforce-mobilisation programmes for Education

Building an Education Pipeline?
Start with the Vetting.

ECRIS multi-country coordination, Directive 2005/36/EC general system navigation, and C1-C2 language pipeline — three workstreams, initiated simultaneously from programme start.

Start Planning