Who is entitled to automatic recognition, and does citizenship matter?
In the United Kingdom
Your citizenship does not make a difference for the purposes of professional registration as a Doctor, Nurse, Midwife, Dentist, Pharmacist or Veterinary Surgeon in the United Kingdom. More specifically, you don’t have to be a European citizen.
However, to be entitled to automatic recognition of your primary qualification (degree), your degree must be
- from a University in one of the European Union’s member states, Switzerland, Norway or Iceland
- and a Relevant European Qualification.
For holders of non-European degrees the usual registration route is through an exam.
- For doctors it is called the PLAB.
- For dentists it is the ORE.
- For nurses and midwives it’s the Test of Competence.
- Pharmacists have to pass the OSPAP and complete a year of training.
- And, finally, Vets have to pass the Statutory Membership Exam.
There may be exemptions to the above, so it’s important to check carefully before making a plan.
The UK can also recognise your specialist qualification without PLAB (e.g. medical or dental specialty) so long as it, too, is a Relevant European Qualification.
If your specialist qualification isn’t a Relevant European Qualification in the UK’s list, then it will not be recognised automatically. There may be a route open to you called the Portfolio Route, depending on your circumstances and any prior UK professional qualifications (e.g. MRCS). We can provide individual advice to help you assess whether it’s worth recognising your specialist qualification in the UK or not, when and how to do it.
In Ireland
Ireland is a member state of the European Union, and that means that it follows European Directive 2005/36/EC which protects the right of European citizens who perform regulated professions.
Under EU Directive 2005/36/EC, your citizenship does matter, as opposed to the UK. Citizens of European Union member states and those who enjoy equal EU rights can have their primary qualification (i.e. University degree) recognised in Ireland as follows:
- Through the Automatic System of recognition. This applies to Doctors, Nurses, Dentists, Pharmacists, Midwives, Veterinary Surgeons whose degree conforms to specific minimum requirements. Most degrees issued in the European Union do meet these requirements.
- Through the General System of recognition. This applies to all other regulated health professions, such as Psychologists and Physiotherapists. This is a more complicated and uncertain route to recognition, but you can definitely benefit from it. We can advise you how.
- Through article 3 of EU Directive 2005/36/EC, provided that you are an EU citizen, and you got your degree from a third country (e.g. the US, Russia or Serbia), and your degree has been recognised already in another EU member state, and you have already practised sufficiently long in that member state. This is a complex route, so consider booking a career consultation with UKmed.
Similarly, Ireland will recognise an EU citizen’s specialist qualification under the Automatic System as long as it appears in EU Directive 2005/36/EC.
If your specialty does not appear in the EU Directive, then it cannot be recognised through the Automatic System. In that case, Ireland’s regulators follow their own national processes and will usually require a lot of evidence from you. Special recognition rules apply in Ireland for specialist qualifications achieved in the UK and other countries. Contact us for an individual consultation.