The European Economic Area (EEA) came about on on 1 January 1994 and consists of the countries in the European Union (EU) and European Free Trade Association (EFTA). EFTA countries are bound by and benefit from, the majority of European Community (EC) legislation, including that which relates to free movement and the mutual recognition of professional qualifications.
This legislation has led to greater opportunities for doctors in Europe. Although the practicalities of employment vary from country to country, doctors are entitled to full registration in any country in the EEA providing:
- they are citizens of a member state and
- they have completed primary training in a member state and hold a recognised qualification
An agreement between Switzerland, the EU and its member states on the mutual recognition of professional qualifications came into force on 1 June 2002. Under this agreement doctors are entitled to full registration in Switzerland provided they fulfil the aforementioned two criteria.
Countries in the EEA are:
Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland (EFTA), Ireland, Italy, Latvia, Liechtenstein (EFTA), Lithuania, Luxembourg, Malta, The Netherlands, Norway (EFTA), Poland, Portugal, Romania, Slovakia, Slovenia Spain, Sweden, and the United Kingdom.
Doctors with non-EEA qualifications
There are doctors in the UK who trained in countries outside the EEA, but who are British citizens and are registered and in practice here. These doctors are not at present fully covered by the legislation described earlier in this section; there is nothing to prevent other countries from accepting them for registration, but equally they have no automatic right to it. Their applications have to be assessed on an individual basis. Doctors from other member states in a similar position have to follow the GMC’s procedure for international medical graduates, rather than that for EEA doctors.
The Directive on Professional Recognition entitles holders of third country qualifications to benefit from the Directive if their qualifications have been recognised by a first member state according to its national rules and they have practised the profession for at least three years in that member state.
Employment conditions and union representation
Obviously, conditions of employment vary from country to country. BMA members who have worked abroad for UK-based organisations may receive help from the association on their return if there is any dispute. However, in other cases doctors are strongly advised to join an appropriate professional association in the host country.
Finding a post
Arrangements for finding posts vary from country to country. A few have vacancy bureaux which may help, but in most, as in the UK, posts are advertised in professional journals.
Doctors should look carefully at factors such as the organisation of healthcare and workforce planning before deciding to move to a particular country. Patterns of work vary greatly, and may bear little resemblance to those common in the British health service. Some EEA member states also have severe problems with medical un- or underemployment, which may make it hard to find posts or to make a living in independent practice.
Temporary work: exchange scheme
Some hospitals or health authorities may have twinning schemes, or it may also be possible to make contacts via town twinning schemes. The Anglo-French and Anglo-German Medical Societies are also able to help with exchange visits.
Other opportunities for doctors in Europe
Doctors occasionally ask about opportunities within European institutions, such as the European Commission, the Council of Europe or the European Regional Office of the World Health Organisation. A few opportunities exist, but these normally involve individuals who are seconded for their special expertise, often on short-term contracts. Other posts are advertised sporadically in the BMJ or in the 'international appointments' pages of national newspapers. Recruitment to permanent posts in EU institutions is a lengthy process, usually involving competitive examinations.
Language barriers are probably a major factor in discouraging UK doctors from working in other European countries. Legislation addresses the question as follows, but without providing any practical guidance:
'Persons benefiting from the recognition of professional qualifications shall have a knowledge of languages necessary for practicing the profession in the host Member State.'
In the UK, EEA doctors are exempt from the International English Language Testing System (IELTS) and the Professional and Linguistic Assessment Board (PLAB) test which international medical graduates must take in order to register with the GMC. Nevertheless, a doctor who is unable to speak and understand the language of the host country is unlikely to be employed or to succeed in independent practice; there is general agreement that it is an ethical requirement to learn the relevant language.
Some doctors plan to practise in holiday resorts and to treat only English-speaking holiday makers or expatriates. Even so, it will still be necessary to liaise with hospitals, pharmacies etc, as well as to complete all the formalities involved in establishing a practice and to cope with the everyday demands of life in a foreign country. Members are, therefore, advised to learn as much of the language as possible.
Most British doctors will have been following science-based courses since the age of 16 and will have had few opportunities to study a language to an advanced level. It may be difficult to find language courses, which are geared specifically to the needs of doctors, but interest in languages for medicine is increasing and opportunities may do so with it. It is worth contacting local colleges to see whether they know of any language tutors locally. You may like to try the following British Council equivalents that provide language instruction:
Mutual recognition of qualifications: EC law
Legislation allowing doctors to move freely within the EC (Free movement of professionals, European Commission) was adopted in 1975 and has been in force since 1976. Under this legislation, doctors are entitled to full registration in any EU member state if they fulfilled the above criteria of being a citizen of a member state and have completed training in a member state and hold a recognised qualification.
Doctors who fulfil the criteria and have completed their specialist training are also entitled to be recognised as specialists elsewhere, but their position is less clear-cut. The legislation contains a list of specialties, which are common to all member states, and a list of those, which are common to two or more. The lists are not exhaustive, and a number of specialties, which are recognised in the UK, are not included at present.
Specialists in areas which are either not listed in the legislation or not recognised as independent disciplines in the countries in which they wish to work will have to negotiate with the host country and possibly undergo some further training. Minimum training periods are specified for each listed specialty. In most cases, these are shorter than those in the UK and there are hopes that they will be extended.
A further directive (86/457/EEC) on specific training for general practice, was adopted in 1986 with the aim of remedying an imbalance in requirements in different member states. It took full effect on 1 January 1995. All those wishing to enter general practice in 'social security' systems (the NHS and comparable publicly funded systems) must have completed a minimum period of specific vocational training. The minimum period is currently in transition from two to three years.
Each country in the EEA has to recognise the certificates awarded by other countries. There are also special exemptions for doctors who on 31 December 1994 held basic medical qualifications listed in the 1975 directives, giving the right to practise without evidence of formal qualifications in general practice. These doctors have what are known as 'acquired rights'.
Professional codes and general information
Doctors must abide by the professional and ethical codes of the countries in which they practise. However, these may differ from those in the UK. There may be significant variations in areas such as confidentiality, access to records or advertising. Migrants should also be aware of the range of cultural, geographical, religious and political factors, which may affect both professional attitudes and patient expectations in different countries.
Registering authorities and bodies equivalent to the BMA in Europe should be contacted for more detailed advice about ethical codes, contracts etc.
Each member state has a body nominated to process applications for registration by doctors from other EEA countries. This is known, in the terms of the legislation, as a 'competent authority'. The competent authority for the UK is the General Medical Council (GMC).
If you wish to work in another EEA country you should contact the relevant competent authority for information about formalities and documents. Medical associations may also be useful sources of information. If you wish to be registered as a specialist you will need to hold either a certificate of completion of specialist training or certificate of completion of training (CCST/CCT) or a certificate of equivalence issued by the Specialist Training Authority. These replace the certificate of specialist training (CST) which was issued by the GMC until January 1996.
There is no centralised registration procedure and each country follows its own cultural and bureaucratic traditions. The type and volume of bureaucracy involved in registration varies from country to country, but doctors should plan well in advance and allow plenty of time for formalities to be completed. These may be daunting, but have to be accepted unless obviously unreasonable and illegal. Be prepared to have all relevant documents translated into the language of the host country. Embassies should be able to provide contact details for official translators based in the UK.
Some countries will also ask for documents which do not exist in the UK. Problems posed by the latter can usually be overcome by common sense and a telephone call to the authority which has asked for them; requests for proof of good character, or similar, are usually satisfied by the certificate of good standing issued by the GMC, and a 'certificate of nationality' may well turn out to be a passport.
EC law requires authorities to process applications within three months, but some doctors experience problems in starting the process. Some medical councils respond more rapidly than others to initial enquiries. If you have professional contacts in the country in which you wish to register, it is a good idea to seek their help.
EEA competent authority list
The following organisations may prove helpful.
General Medical Council
350 Euston Road
London, NW1 3JN
Tel: 0845 357 8001
Fax: 0845 357 9001
Email: [email protected]
Anglo-French Medical Society
Secretary: Dr Mark Cottrill
Email: [email protected]
Anglo-German Medical Society
Email: [email protected]
Medicine in Germany
Italian Medical Society of Great Britain
Prof Salvatore M. Aloj, Scientific Attaché, Embassy of Italy
Email: [email protected]