Mixed views on the EP’s resolution “Strengthening the Single Market: the future of free movement of services.”


The Architects Council of Europe represents and supports 575,000 architects working across Europe. European architects and their clients benefit from the Professional Qualifications Directive (PQD), which allows many architects to move freely to work and study across the EU. EU architects and their clients benefit from the exchange in research, building standards and innovation that is being achieved through the common standard and the ability to work freely across the 27 countries.

The Architects' Council of Europe notes the publication of the report from the Internal Market & Consumer Protection (IMCO) Committee “Strengthening the Single Market: the future of free movement of services, recently approved by the European Parliament, with mixed views.

ACE welcomes the call to improve the performance of the Points of Single Contact and plans to implement the Single Digital Gateway, which could assist cross-border service suppliers.

ACE also welcomes statements recognising the success of the Professional Qualifications Directive, that professions are regulated in the public interest and that the automatic recognition enjoyed by these regulated professions, under the provisions of the PQD, has assisted in satisfying cross-border registration requests – in over 90% of cases relating to architects, as shown by the Commission’s regulated professions database.

ACE agrees that improvements could be made to the Public Procurement Directive to provide more opportunities to architects who are, by huge majority (>95%), small and medium enterprises, and who are currently, de facto, excluded from procurement markets for a variety of reasons: excessive turnover and experience requirements which, given the average size of architectural practices, currently exclude over 90% of companies from the market. We look forward to the next review of the Directive which should put a stronger focus on quality-based selection procedures.

ACE also agrees that stricter implementation of the Services Directive could help to achieve the objective of guaranteeing the quality of services of general interest for the benefit of consumers. However, our views start to diverge regarding the approach to be taken. Whereas the report speaks of enforcement and infringements, we would encourage the legislators to promote the voluntary convergence elements of the Directive. To this end, ACE has already developed a quality charter, explored quality management systems, mutual recognition of insurance provision and approved a non-binding deontological code for cross-border service suppliers.

While acknowledging the possible merits of a European Professional Card (for those without automatic recognition under the PQD), we would stress that the EPC is only meant to made available to those professions that request it.  It is not something to be imposed and ACE would caution against any measures that add bureaucracy and administrative burdens without any benefit to service providers or their clients.

We do not share the Parliament’s “regret” that the Member States rejected the proposal for a new Notifications Directive which would have reversed the burden of proof regarding the suitability of new regulation (transferring that burden from the Commission to the Member States). The current provisions of the Services Directive are adequate.

Nor do we share the view that different regulatory approaches have led to an enforcement gap – on the contrary, if the Regulatory Restrictiveness Indicator developed by the Commission took into account, adequately, not only ex ante regulation but also ex post regulation, it could become clearer that the differences are not necessarily barriers per se. Therefore, we welcome the invitation from the Parliament to the Commission to undertake a qualitative and quantitative review of existing indicators involving all stakeholders and hold ourselves ready to participate.

Download the ACE statement.

The Architects’ Council of Europe (ACE) is the representative organisation for the architectural profession at European level: it aspires to speak with a single voice on its behalf in order to achieve its aims. Its membership currently consists of 43 Member Organisations, which are the regulatory and professional representative bodies in EU Member States, Accession Countries, Switzerland and Norway). Through them, the ACE represents the interests of 575,000 architects from 30 countries in Europe.

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