A government signs a regional trade agreement that commits it to the free movement of professional services. The political work is done, the agreement is celebrated, and then a lawyer, an engineer, vet, doctor or an accountant qualified in one jurisdiction moves to another and discovers they effectively cannot practise. The commitment exists on paper, but the recognition does not exist in fact.
The instrument meant to close that gap is the Mutual Recognition Agreement (MRA). It is also one of the most under-delivered tools in services trade; widely signed, frequently announced as evidence of integration, but often far less made to work as intended. The reason it stalls is rarely political. More often than not, it stalls in the technical space that accrediting bodies, regulators and quality-assurance agencies occupy where the detailed work of comparing what two qualifications require, deciding whether they are genuinely equivalent, and standing behind that judgement, take place. Negotiators can open the door but only the accrediting and regulatory community can make it safe to walk through.
What an MRA asks of an accreditor
Stripped of the jargon, an MRA is an arrangement under which a qualification, registration or licence earned in one jurisdiction is recognised in another, so that a professional who meets the standard in country A is accepted as meeting it in country B without requalifying from scratch. For a trade negotiator that is a market-access commitment. For an accrediting or licensing body it is something far more demanding, a request to vouch for practitioners you did not train and do not directly oversee.
“Recognition” is also not a single thing, and choosing the right form is itself an accreditation judgement. It runs along a spectrum from full assimilation, where a foreign professional is treated exactly as a local; through the right to practise under a home title with a limited scope, common for lawyers; to temporary or project-based recognition for short-term work. Each point on that spectrum carries a different level of risk and therefore a different level of due diligence. Much of the difficulty in designing an MRA comes down to matching the form of recognition to each profession, rather than applying one model across the board.
Why recognition stalls
Several forces pull against a working MRA, and almost all of them lead to the bodies that accredit and regulate.
Differing standards. Two countries may both produce competent professionals while training them quite differently; different curricula, different assessments, different scopes of practice. Establishing genuine equivalence, rather than assuming “qualified” means the same thing on both sides, is precisely the work accrediting bodies exist to do.
Regulatory trust. A regulator is accountable for the professionals it admits, so accepting practitioners trained and overseen elsewhere means extending trust to a counterpart’s system. That trust cannot be declared in a treaty; it is built regulator to regulator, through sustained contact, shared methodology and mutual confidence in one another’s quality assurance.
Protectionism. Established professions do not always welcome new entrants, and domestic interests can quietly resist implementation. A credible, transparent equivalence process led by the accrediting body is the best answer to the suspicion that recognition lowers standards.
The implementation gap. Signing an MRA is a political act; implementing it is a technical and administrative programme that can run for years agreeing equivalence, adapting registration processes, and training the people who will operate the new arrangements. This is overwhelmingly the accrediting and regulatory community’s workload.
Bridging the academic and professional worlds
One distinction matters more to this audience than any other. Academic recognition and professional recognition are related, but they are not the same, and the gap between them is where a great deal of mobility is won or lost. A degree may be deemed academically comparable across borders without conferring any right to practise; conversely, a licence to practise rests on competencies that a transcript alone does not capture.
The EU’s experience illustrates both the opportunity and the limits. The Bologna Process created a comparable three-cycle degree structure across more than forty countries and made professional recognition easier by improving transparency between higher-education systems. But it was a voluntary, intergovernmental effort without legal force, and its implementation was uneven. The lesson is not that academic alignment is unimportant but that it does not, on its own, deliver the right to work. Bridging the two worlds is work that academic quality-assurance agencies and professional accreditors must do together, mapping learning outcomes to professional competencies, agreeing where a degree ends and licensing begins, and designing the bridging or compensation measures that close any genuine gap. Bodies that sit across both worlds or that build deliberate links between them, are the ones best placed to make an MRA function.
A live development: the UK/EU reset
These arrangements are never static, as the UK and EU post-Brexit negotiations are demonstrating. Since 2021, EU rules on professional qualifications no longer applied to the UK. Automatic recognition ended and professionals moving in either direction had to satisfy each jurisdiction’s rules individually. The UK–EU Trade and Cooperation Agreement left only a route to future profession-by-profession arrangements rather than recognition itself and that route runs directly through the regulators. Under it, the regulators of individual professions are invited to put forward recommendations for recognition arrangements for the two sides to adopt. In other words, the initiative now sits with accrediting and regulatory bodies.
The 2025 UK–EU “reset” has established dialogues on professional qualifications, but progress here has been slower than on other strands precisely because it depends on this detailed, regulator-led groundwork. The practical implication is clear, bodies that prepare their equivalence evidence and build relationships with their counterparts now will shape the arrangements that eventually emerge.
What makes one work – a practical checklist
Across every region that has attempted this, the MRAs that succeed share a recognisable groundwork which accrediting bodies and regulators are uniquely placed to lay.
Start with equivalence mapping. Undertake a genuine technical comparison of what each qualification requires and delivers, surfacing real differences rather than papering over them, and name the gaps openly.
Address gaps deliberately. Design proportionate bridging or compensation measures, adaptation periods, aptitude tests, supervised practice rather than either ignoring differences or treating them as disqualifying.
Invest in regulator-to-regulator trust. Build it through sustained contact, joint working and shared infrastructure, so recognition rests on confidence in one another’s systems rather than on hope.
Connect academic and professional recognition. Map learning outcomes to professional competencies so a qualification’s academic comparability translates into a defensible licensing decision.
Tie recognition to the mechanics of mobility. Recognition not linked to work permits, visa systems and digital tools; e-credentialing, professional cards, shared registers will not, on their own, let anyone work.
Phase realistically. Start with a few high-demand professions and scale up as confidence builds; full mutual recognition is a destination reached in stages, not a switch thrown on day one.
In our experience
None of this is theoretical. We have advised governments, regulators and regional bodies on Mutual Recognition Agreements across a range of professions including law, veterinary services, architecture, accountancy and engineering. This has included feasibility studies and the facilitation of negotiations to the training of regulators and the professions and recommendations on implementation. That work has spanned the EU, ASEAN and several African regional trade agreements. The pattern holds throughout, the agreement is the easy part, and the technical, accreditation-led groundwork around it is what determines whether a trade commitment becomes a working reality.
