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Post-Brexit recognition of professional qualifications

Helpsheets and support

Published: 09 Mar 2021 Update History

ICAEW is committed to helping members seeking professional recognition for the pursuit of regulated activities, such as statutory audit, in the European Economic Area (EEA) under the post-Brexit arrangements. ICAEW members seeking recognition in the EEA are advised to contact us with individual cases to see how we might be able to help.

The EEA extends the EU Single Market for EU member states to Iceland, Norway and Liechtenstein and therefore is impacted by the UK departure from the EU. We suggest contacting ICAEW because the situation differs across EEA states given that national rules apply in some cases, without a recognition regime covering all EEA states.

We hope that such a regime will be in place in the near future under the Trade and Co-operation Agreement (TCA) signed between the UK and EU. However, as most accountancy services outside of statutory audit are not regulated across the EEA (ie, not subject to market access rules and a requirement to have a professional affiliation etc), the lack of an EEA-wide recognition regime will have a limited impact on ICAEW members.

ICAEW is also committed to assisting EEA professionals who wish to gain the ACA qualification to practise regulated activities in the UK and/or for ICAEW membership benefits. For those wishing to provide audit services, we are working with the UK Government to confirm the audit recognition route anticipated in UK legislation for EEA professionals. ICAEW will also continue to grant access to the ACA qualification under the Common Content Project and the UK’s Recognition of Professional Qualifications Regulations (RPQ Regulations) for those seeking to provide other services in the UK under the ICAEW Chartered Accountant title.

The information contained here does not address visa and residency requirements which will need to be respected in the EEA and UK for migrating professionals.

Recognition with the Republic of Ireland differs from other EEA states – please visit our page on Revocation of ICAEW’s Recognised Accountancy Body (RAB) status in Ireland for further details on Ireland specifically.

Outgoing recognition of ICAEW members in the EEA

How do I apply for audit recognition in the EEA as an ICAEW auditor from 1 January 2021?

If you now wish to apply for recognition in the EEA, you should contact us as we may be able to advise on provisions which exist nationally within the EEA for the recognition of the ACA or other provisions which facilitate recognition.

ICAEW is also working with the UK Government on forming new recognition routes available under the TCA as well as the potential pursuit of bilateral agreements between the UK and individual EEA states for the reciprocal recognition of auditors. The TCA provides an inter-governmental mechanism – the ‘Partnership Council’ – to negotiate recognition agreements which are pan-UK and pan-EU in application and therefore also applicable for the EEA. We are aware that this process may require some time although we are calling on UK government to prioritise it. For this reason, bilateral agreements may be timely and relevant and there is provision for them within EU legislation.

For ICAEW students in EEA countries, we have a number of in-country agreements which are relevant for the recognition of ICAEW’s ACA qualification where the pursuit of regulated activities is concerned. In turn, a number of countries have broad arrangements embedded in legislation for the recognition of so-called ‘third country’ qualifications, which also encompass the ACA. Please contact ICAEW if you would like further information or help on this point.

Is professional recognition required to provide accountancy services outside of audit in EEA states?

Most accountancy services are not regulated in the EEA, therefore you may not need to apply for recognition if you wish to provide unregulated accountancy services in the EEA. However, where they are regulated, there may be a recognition route available through national legislation so please contact ICAEW as we may be able to help with your recognition. You may also wish to make enquiries yourself with the relevant competent authority which can be found on the EU’s Regulated Professions Database.

Will my ACA qualification continue to be recognised in the EEA if I achieved recognition before 31 December 2020?

Yes, the provisions of the Withdrawal Agreement between the UK and the EU confirm that recognition will continue for non-regulated and regulated activities providing you are a UK/EEA national and can satisfy residency requirements. You will also be able to complete the recognition procedures from 1 January 2021 if you made a full application before 31 December 2020 but had not yet completed the requirements imposed by the EEA state.


Incoming recognition of EEA qualifications in the UK

How do I apply for audit recognition in the UK with ICAEW from 1 January 2021?

It is the UK Government (the Department for Business, Energy and Industrial Strategy (BEIS) and the Financial Reporting Council (FRC)) who controls overall access to audit recognition in the UK. Although there is no audit recognition currently agreed for EEA auditors applying from 1 January 2021, ICAEW is working with BEIS, FRC and other UK recognised qualifying bodies to create these provisions under the TCA or via bilateral agreements. This could allow similar recognition as was available when the UK was part of the EU and we will continue to encourage this forward from a UK perspective. It must be emphasised that BEIS and FRC will be driving the process on the UK side as they are the formal authorities under the Companies Act 2006. ICAEW is happy to advise EEA-qualified individuals and their employers on ICAEW membership/registration matters as appropriate.

Is professional recognition/ICAEW’s ACA qualification required for the provision of accountancy services outside of audit in the UK?

As most accountancy services are not regulated in the UK, you may not need to apply for any formal recognition. However, many accountancy roles will require a formal qualification, such as ICAEW’s ACA qualification, which may be available to you under the Common Content route or the UK RPQ Regulations.

Common Content

ICAEW will continue to recognise members of the Common Content Project in the UK. ICAEW is a founding member of the project which is a collaboration between premier accountancy bodies in Europe with an aim to further develop, maintain and unify high-quality professional accountancy education benchmarks. This provides members of Common Content bodies access to ICAEW’s ACA qualification without completing any additional educational or practical experience requirements.

UK RPQ Regulations

The UK Government has facilitated the continued recognition of EEA qualifications under the RPQ Regulations. This provides a route towards ICAEW’s ACA qualification if you hold an EEA or Swiss qualification and ICAEW assesses that qualification as comparable in scope, level, and content as the ACA qualification. The outcome of this assessment will determine the aptitude test required to bridge the gap between the qualifications and obtain the ACA qualification. The practical experience obtained during your home body qualification will be fully recognised so there are no additional practical experience requirements under this route. 

Will my EEA qualification continue to be recognised by ICAEW in the UK if I achieved recognition before 31 December 2020?

Yes, the UK Government has agreed that recognition will continue for non-regulated and regulated activities. You will also be able to complete the recognition procedures from 1 January 2021 if you made a full application with ICAEW before 31 December 2020 but had not yet completed the necessary compensation measures.