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While the stakeholders welcomed the updating of the minimum training requirements, concerns were raised about the provisions in this area being too prescriptive and the need for more flexibility. They were also concerned that their involvement in the preparation of any delegated acts, which seek to modernise these minimum training requirements, should be assured from the outset.
All of the stakeholders emphasised the importance of continuing professional development (CPD) in terms of ensuring the continued competence of professionals. However, while some regretted that it was not mentioned in the proposal, others agreed with the Commission's omission due to concerns about any such references being too prescriptive, emphasising that CPD should remain primarily a concern for the relevant competent authority to regulate. The stakeholders reiterated the recommendation in their report that there should be a reference to CPD in the general framework of the Directive.
The stakeholders welcomed the Commission's desire for the more widespread use of the Internal Market Information system (IMI), as well as the introduction of an alert mechanism. However, they did not understand how the alert mechanism could be restricted to the automatically recognised professions and not the general professions. They also stressed that the mechanism should also flag up any conditions, restrictions or limitations placed on an individual's right to practise rather than just removals from registers. They share the concerns in this regard. They also share the Government's concerns about the data protection implications and welcome DBIS's intention to ensure that this aspect is examined closely during the negotiations.
Like the Government, the stakeholders were also enthusiastic about the proposed transparency exercise whereby each Member State will review their regulated professions on the basis of proportionality and necessity and report these to the Commission, before undertaking a peer review process. However, they had concerns about whether each Member State's regulatory or representative bodies would fulfil that role, particularly as these competencies varied between and within Member States.