Summary

Overall Approach: We support the European Commission‟s overall objective to facilitate the movement of practitioners between Member States. However it should be equally important that this exercise does not undermine professional standards that are in place to protect the public interest.

Professionalism Increasing in Insurance and Financial Services: We think that the concept of “professionalism” (involving holding formal qualifications, mandatory continuing professional development and ethical responsibilities, and being a member of a professional body) is becoming increasingly important in our industry. It is driven by statutory financial regulation to improve consumer protection and industry efforts to raise public trust and confidence.

Potential for Increased Incidence of Practitioner Migration: EU-wide corporate activity in our sector is resulting in more financial services and insurance firms having major operations in several Member States. This will increase the volume of cross-border migration as those firms move their professional staff around their corporate groups for career development purposes.

Mutual Recognition More Complex: The move towards professionalism described above will require more carefully developed processes for recognising qualifications. Whereas previously it may have simply been a question of verifying experience, it is starting to be more about recognising and accrediting professional qualifications. This is especially the case with sectors in some Member States which will move towards professionalism faster than others.

Automatic Recognition Based on Experience: We believe this provision in the Directive is not consistent with regulatory and industry-led efforts to improve public trust and confidence. This provision should be overhauled to ensure that the exercise to improve cross-border access does not undermine standards in those Member States that already require formal qualifications.

Develop European Role-Based Competency Frameworks for Each Sector: Iin support of the Commission‟s new proposal on Euro-curricula, we propose that common “European role-based competency frameworks” be developed in each sector. These would set out knowledge, skills and conduct elements for each role, thereby providing a framework against which a migrant's national qualification standing could be matched. We are willing to work with other European competent authorities in our industry to help bring this about.

CII Consultation Response