Europaudvalget 2015-16
EUU Alm.del Bilag 264
Offentligt
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Note
The Danish National Action Plan - Evaluating national regulation on
access to professions
07 January 2016
Danish Agency for Higher
Education
Bredgade 43
1260 Copenhagen K
Denmark
Phone
+45 7231 7800
Fax
+45 7231 7801
E-mail
[email protected]
Website www.ufm.dk/en
CVR no.
3404 2012
Table of contents
Introduction
............................................................................................................... 2
Chapter 1 – Process for the Danish transparency exercise
......................... 4
Task force for regulated professions ............................................................................ 4
Cooperation with other Member States: Frontrunners initiative ............................... 5
Nordic Councils of Ministers ........................................................................................ 5
Chapter 2 – Review of the Danish regulated professions
............................ 7
Cluster 1 – BUSINESS SERVICES ............................................................................... 8
Cluster 1 - CONSTRUCTION ...................................................................................... 24
Cluster 1 – MANUFACTURING ................................................................................. 34
Cluster 1 – REAL ESTATE .......................................................................................... 35
Cluster 1 - WHOLE SALE AND RETAIL .................................................................... 38
Cluster 2 – PUBLIC SERVICES AND EDUCATION ................................................. 40
Cluster 2 – FINANCIAL SERVICES ........................................................................... 52
Cluster 2 – HEALTH AND SOCIAL SERVICES ........................................................ 57
Cluster 2 – NETWORK SERVICES ............................................................................ 63
Summary – Review of the Danish regulated professions ......................................... 66
Chapter 3 – Conclusion ........................................................................ 70
Responsible
Anne Larsen
Phone
+45 72318919
E-mail
[email protected]
Ref. no.
Dokument nr.
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Introduction
Denmark recently carried out a national transparency exercise which corresponds
to Article 59 of the revised Professional Qualification Directive (2013/55/EU). An
examination of the Danish regulated professions has thus been carried out in
accordance with Communication from the Commission, COM (2013) 676, dated 2.
October 2013.
1
Denmark has about 120 regulated professions and about 40 medical specialties all
registered in the EU database for regulated professions (under the Professional
Qualification Directive) according to the latest update. The average number of
regulated professions per Member State is currently estimated at 157.
The first and initial action plan on the regulated professions included in the first
cluster (Business services, Construction, Manufacturing, Real estate, Transport,
Wholesale & retail) was sent to the Commission in September 2015. This second
and final action plan is based on the initial National Action Plan integrating any
further steps or developments arising since the first submission for cluster 1 profes-
sions as well as introducing the intentions for those professions falling under clus-
ter 2 sectors
2
(Public Services and Education, Other, Financial Services, Health and
Social Services and Network Services).
The descriptions of the professions and their actions are further developed after the
feedback from the Commission to the first and initial Danish action plan.
To give a complete and thorough overview of the Danish regulated professions and
the actions, all professions under Cluster 1 and 2 are included and described in this
report.
This final action plan is structured the following way: chapter 1 describes the
process that has taken place in Denmark in order to make it easier to be established
or provide temporary services as a professional and/or enterprise. In 2013, parallel
to the EU transparency exercise under the Services directive and (now revised)
Professional Qualification Directive, the Danish Government established a task
force for regulated professions as a part of the Government’s competitiveness
policy package. The purpose of the task force for regulated professions was to
examine whether the requirements for access to regulated professions in Denmark
are e.g. necessary, proportionate and justified. This process has initiated several
initiatives/actions with the objective to deregulate, modernise and/or simplify
certain regulated professions and professional fields with reserved activities. Some
initiatives/actions were already initiated before the establishment of the task force
and the beginning of the transparency exercise.
Chapter 1 also reports about Danish participation in the Frontrunners project at EU
level and in a common political initiative at Nordic level with the purpose to
Danish Agency for Higher
Education
1
Communication from the Commission to the European Parliament, the Council and the European
Economic and Social Committee on Evaluating national regulations on access to professions,
COM(2013) 676 final, dated 2. October 2013
2
Commission Working Papier “Next steps: National Action Plans”, GROW/D4 19/01/2015
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improve the functioning of the Single Market for companies and citizens in
practice.
Chapter 2 in this report includes a review of the cluster 1 and 2 professions. It
highlights the actions that have taken place or are expected to take place regarding
the regulated professions in Denmark in order to ensure proportionate, necessary,
justified and non-discriminative regulations of the professions. The review of the
professions is followed by a summary which concludes on the actions and
categorises them in relation to which kind of action that has taken place – if any.
The actions include deregulation in the form of lift of reserved activities,
simplification, modernisation, mergers, further digitalisation etc. An ‘action’ in the
report is described to be an action (deregulation) when it affects the possibility to
get access to work as a professional.
Proportionality of the legislative acts regulating access to and exercise of the
regulated profession is subject to regular control of all draft legislation in Denmark
and was evaluated again as a part of the transposition process during 2015.
Chapter 3 concludes on the actions Denmark is carrying out in order to make it
easier to work as a professional in Denmark.
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Chapter 1 – Process for the Danish transparency exercise
Task force for regulated professions
In October 2012, the Danish Government presented a competitiveness policy
package
3
in which it was concluded that competitiveness and productivity within
both the retailing and construction sector could be strengthened and improved.
One priority area was how to promote competitiveness in relation to domestic
service professions, e.g. real estate agents as well as authorisation schemes for
electricians, plumbing and construction. On this background, the Government
established a “task force for regulated professions” in the beginning of 2013 also
linking it to the forthcoming transparency exercise. The purpose of the
interministerial task force was to facilitate a screening of the regulated professions
in Denmark and give concrete proposals as to where it would be relevant to remove
unnecessary regulation or to introduce more simplified regulation related to the
access to exercise and pursue certain regulated professions. Hereby, the work of the
task force and its results and recommendations also served as an important
contribution to the Danish transparency exercise.
The project of establishing the task force and coordinating the screening process
was led by the Ministry of Business and Growth. 13 ministries participated in the
review of the regulated professions for which those ministries are responsible.
External consulting support contributed to this work. As part of the work the task
force held meetings and carried out a comprehensive questionnaire among the
relevant ministries. The questionnaire included questions which focused on the
different professions’ and schemes’ regulation, the purpose of the regulation, the
economic turnover, the number of authorisations/certificates etc. in each
profession, requirements in the profession and expressions in relation to how
deregulation is initiated in other fora with the purpose of creating more simple and
competitive rules. The task force identified around 170 schemes related to 120
regulated professions in Denmark.
According to the Danish Business Authority, regarding 18% of the regulated
professions initiatives to remove regulatory restrictions were already being taken,
regarding 68% of the regulated professions the competent ministries found that
there was no need to change legislation at present, and the remaining 14 % of the
regulated professions had potential for change of regulation or schemes.
The results of the task force served as part of the preparation – but also as concrete
input into the governmental Growth Act/Vækstpakke 2014
4
. The Ministry of
Finance has the responsibility for the Act which contains requirements for certain
levels of simplification of the rules for access to regulated professions, for instance
regarding easier access to the professions in the construction sector. For that
purpose, the Government launched, among other things, an analysis of
authorisation schemes for structural engineers and land surveyors with the aim of
removing administrative burdens and entry barriers. Moreover, the Danish
Danish Agency for Higher
Education
https://www.evm.dk/~/media/oem/pdf/2012/pressemeddelelser-2012/26-10-12-
konkurrencepolitisk-udspil/26-10-12-konkurrencepolitisk-udspil-pdfa.ashx
4
http://www.fm.dk/publikationer/2014/danmark-helt-ud-af-krisen-_-virksomheder-i-vaekst
3
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Government proposed modernisation of a range of business services, such as
translator/interpreter, offshore-professions, lift inspection etc.
Cooperation with other Member States: Frontrunners initiative
In collaboration with Sweden, Norway, Lithuania, Estonia, the Netherlands, the
United Kingdom and Portugal, Denmark has participated in the Frontrunners ini-
tiative on professional qualifications which aims at developing the work of the
transparency process further by sharing experiences and knowledge and offering
non-binding guidance to member states when assessing the regulation of profes-
sions. The project builds on studies analysing the economic impact of regulated
professions as well as case studies provided by the participating Member States and
coordinated by the United Kingdom. Furthermore, the project highlights factors
which should be taken into consideration when assessing regulated professions and
offers guidance as to: a) when regulation is justified and if so what kind of regulato-
ry tools could be considered b) when an alternative to regulating might be pre-
ferred. As a part of this project, there were descriptions of how the electrical, gas,
plumbing and sewer field have been deregulated recently in Denmark. These re-
sults are included in this action plan in the review of the professions, chapter 2.
Danish Agency for Higher
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Nordic Councils of Ministers
Free movement is an important part of the agenda for the Nordic countries. The
Nordic countries have agreed to work closely towards removing cross-border ob-
stacles in order to create jobs and growth in the Nordic region. Therefore, mobility
and free movement plays a crucial role in in Nordic Council of Ministers’ overall
mission and strategy. In October 2013, in a statement on the new strategy and ac-
tion plan for freedom of movement in the Nordic region, the Nordic prime minis-
ters identified four specific goals:
to work for an open and fully functioning common labour market
to create the best possible conditions for Nordic companies to operate
across borders in the Nordic region to ensure, as far as possible, consistent
implementation of EU legislation in the Nordic region through an ongoing
dialogue between the Nordic countries
to work to ensure that countries, when necessary, communicate with each
other - when new regulation is introduced - in order to avoid new barriers.
The Nordic Council of Ministers conducted in 2013 a study on regulated profes-
sions in the Nordic Region (Denmark, Sweden, Iceland, Finland and Norway). The
study was carried out by DAMVAD Analytics and has been completed by the report
“Mobility in the Nordic Region – regulated professions and the welfare sector”
5
,
which among other things mapped out the professions that are regulated in each of
the Nordic countries; described the cooperation between the competent authorities
and identified areas in which cooperation should be strengthened to facilitate an
easier mobility of labour in the region. The study points out that the Nordic coun-
tries have a fundamental interest in promoting freedom of movement in the labour
market. The study also showed that there are large differences in the professions
that the individual Nordic countries have chosen to regulate; the overlap in regula-
5
http://norden.diva-portal.org/smash/get/diva2:720957/FULLTEXT01.pdf
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tion is just 20 %. Those findings led to the broad political agreement that, within
the existing economic frameworks, efforts must be made to:
Reduce the number of existing barriers, in particular the informal ones, e.g.
industry regulation
Preventive initiatives need to be strengthened and citizens and enterprises
need to be actively informed about the existing barriers
The follow-up must take place within the framework of current EU aquis,
including the revised Professional Recognition Directive
Nordic Council of Ministers will continue to facilitate a close Nordic cooperation
with the implementation of the professional qualification Directive and European
Professional Card offering a platform for coordination and exchange of information
on regulated professions in the countries. The aim is to facilitate a good implemen-
tation in the countries securing free movement for citizens and enterprises across
borders in the Nordic region.
As a consequence of new EU regulation regarding free mobility and the single mar-
ket, Nordic Council of Ministers initiated in 2015 a critical review of the Nordic
agreements regulating mobility of labour and education in order to align with EU
regulatives. Concrete plans for revision of the Nordic agreements will be clarified in
2016 on the basis of recommendations from University of Helsinki.
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Chapter 2 – Review of the Danish regulated professions
This chapter includes a review of the regulated professions in both cluster 1 and 2
organised following the economic sectors defined in the Commission
communication of 2 October 2013
6
.
Furthermore, the review follows the guidelines suggested by the Commission
7
and
therefore includes the overview regarding current regulatory framework,
conclusions assessment made, measure(s) proposed and/or implemented,
indicative process to have the measure(s) implemented, timetable for the adoption
and implementation of the measure(s), state of implementation of reform (where
ongoing) and new regulatory framework (if reform recently adopted).
Each profession has been categorised in relation to the type of action (if any) and
whether the action is decided or expected. The categories are the following: 1.
Abolishment of the scheme, change of rules and requirements, change in reserved
activities, 2. Change of administration, further digitalisation, simplified guidance,
modernisation, 3. Merger of schemes, 4. Further regulation, and 5. No action/no
new regulation. Category 1-3 is deregulation that is introduced to make it easier to
get access to work as a professional.
Danish Agency for Higher
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Category
1
Type of Action
Abolishment of the scheme, change of rules and requirements,
change in reserved activities
Change of administration, further digitalisation, simplified guid-
ance, modernisation
Merger of schemes
Further regulation
No action/no new regulation
2
3
4
5
The actions described include both actions that have taken place recently (about 2
years back in time) or are expected/decided to take place in the near future in order
to remove unnecessary regulation or to introduce more simplified regulation.
As mentioned in the introduction, an ‘action’ in the report is described to be an
action (deregulation) when it affects the possibility to get access to work as a
professional.
Under each profession, time frame is only listed if there is anything specific to men-
tion.
6
7
Same as no. 1
Commission Working Papier “Next steps: National Action Plans”, GROW/D4 19/01/2015
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The information about each profession is provided by the relevant competent au-
thority during November/December 2015. Furthermore, the reports from the task
force and the Frontrunners-project are included in this report.
On May 8 2014 Denmark provided to the Commission short sector reports for all
regulated professions under the Professional Qualification Directive. During the
summer 2014 Denmark has notified in the EU-database all existing regulated pro-
fessions. The dabase is regularly updated.
The review is followed by a summary which briefly lists all the regulated profes-
sions in relation to decided, expected and none foreseen actions. Furthermore, the
decided and expected actions will be categorised in relation to the categories intro-
duced earlier so that a complete overview of the Danish actions is given.
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Cluster 1 – BUSINESS SERVICES
Lawyer/ barristor/ solicitor (DA - advokat)
Competent authority: Ministry of Justice, Civil department
Cluster category: Business services
Type of Action: Category 5
Current situation
Lawyers perform various tasks, e.g. representing clients before courts and provid-
ing legal services, including advisory services. The profession as an advo-
cate/lawyer is regulated by reserves of activities. The requirements for a person
who wants to practice law in Denmark are contained in section 119 of the Danish
Administration of Justice Act
8
. This section first and foremost requires that the
person in question must be legally competent, and that the person must not be
under guardianship, restructuring or be in bankruptcy. The person must further
hold a Danish Bachelor’s and Master’s Degree in Law, have carried out practical
legal work for at least three years, have completed a theoretical basic education,
have passed an examination in matters of special importance to the profession of
lawyers as well as a practical test of litigation and have acquired experience in
hearing cases. For persons who hold a Master’s degree in Law from one of the EU
Member States or from a country with which the Community has concluded an
agreement that corresponds to the level of the Danish Bachelor’s and Master’s de-
gree in Law, the Minister for Justice may fix a trial period as a condition for the
candidate’s authorisation to work as an assistant attorney. This will be done to en-
sure that the candidate has the necessary knowledge of Danish procedural law and
masters the Danish language at a level that enables the candidate to conduct oral
proceedings in a proper manner. The same shall apply to persons who hold a Bach-
elor’s degree in Law from one of the EU Member States or from a country with
which the Community has concluded an agreement and who hold a Danish Mas-
ter’s degree in Law, cf. section 135 a (1) of the Danish Administration of Justice
Act
9
.
8
9
Consolidation Act no. 1255 of 16 November 2015
Consolidation Act no. 1255 of 16 November 2015
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The regulation of the lawyer profession has been developed to ensure a high quality
of the legal services provided by lawyers in order to protect consumers and recipi-
ents of services and safeguard the sound administration of justice, especially in
court cases.
New situation/ actions
In 2008, the rules on the monopoly of lawyers to appear before a court in section
260 of the Danish Administration of Justice Act
10
were amended. The amendment
followed a proposal by a working group appointed by the Ministry of Justice in
2004 to review the legislation regarding lawyers. Based on the conclusion from the
working group, the rules were amended: other persons than lawyers were granted
competence to appear before the court in cases concerning claims smaller than
DKK 50.000, in cases concerning payment orders which meet certain requirements
and in cases concerning enforcement of orders in the bailiff’s court. As a conse-
quence of the governmental competitiveness policy programme for 2012 , “Styrket
konkurrence til gavn for Danmark” (EN – “Strengthened competition to the benefit
of Denmark”), the regulation on lawyers has once again been reviewed in order to
establish whether the current regulation is still necessary, e.g. whether the general
interest objective can be reached by less strict measures.
Time frame
The work with the review of the legislation is still ongoing. There is no time frame
for now.
Danish Agency for Higher
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Auditor/accountant (DA - statsautoriseret revisor)
Competent authority: The Danish Business Authority
Cluster category: Business services
Type of action: 1+3+4 (decided)
Current situation
The profession is regulated by Directive 2006/43/EC as amended by Directive
2014/56EU, which in Articles 6-12 establish the basic requirements to be approved
as a statutory auditor. The provisions are implemented into section 3 of the Danish
Act on Approved Auditors and Audit Firms and the Ministerial Order No. 1408 of
11 December 2013. Access to the profession requires:
1) Theoretical education: A master’s degree in auditing or another master which
satisfies some minimum requirements,
2) Practical education: 3 years of practical training, and
3) Passing of an examination of professional competence:
A person who is approved as statutory auditors in another Member State in accord-
ance with regulation implementing the Audit Directive must pass an aptitude test
in accordance with section 10 of the Danish Act on Approved Auditors and Audit
Firms (cf. Article 14 of the Audit Directive.
10
Consolidation Act no. 1255 of 16 November 2015
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The profession is regulated by reserves of activities. The scope of the Act on Ac-
countants is approved auditors’ provision of assurance reports (audit engagements
and other assurance engagements e.g. review) and non-assurance reports e.g. re-
porting on compilation engagements. Any person can provide reporting services
unless legislation requires a report by an auditor. Likewise, accountancy related
activities e.g. bookkeeping, assistance is not restricted to approved auditors or oth-
er authorised persons (reserves of activities). The objectives with the regulation are
protection of consumers and recipients of services, safeguarding the sound admin-
istration of justice as well as protection of creditors.
New situation/ actions
In 2013, the Act on Approved Auditors and Audit Firms was amended. Now, there
only exist one regulated profession in auditing (state authorised public accountant)
– earlier there were two (registered public accountant and state authorised public
accountant). With the amended Act, working as a state authorised public account-
ant auditor requires a master’s degree. The purpose with the amendment was to
strengthen the educational requirements to the auditors, especially those working
with financial businesses and by this strengthen the trust into the financial sector.
The amendment also aimed at modernising the education that had remained the
same for many years.
Time frame
The EU-directive (2014/56/EU) will be implemented by 17 June 2016. In 2013, the
the Act on Approved Auditors and Audit Firms was amended to strengthen the
trust into the financial sector. There are no further actions foreseen at national
level.
Danish Agency for Higher
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Energy engineer (DA – energikonsulent)
Competent authority: Danish Energy Agency
Cluster category: Business
Type of Action: 4 (decided)
Current situation
The profession is regulated by reserves of activities according to the Ministerial
Order on the change of ministerial order on energy labelling of buildings
11
. The
energy performance certificate assigns an energy performance label to nearly all
types of buildings and lists cost-effective measures for improving their energy per-
formance. The energy label classifies the building on an efficiency scale.
The requirements for this profession are strictly related to the task. Since May 2011,
an Energy Performance Certificate can be issued only by certified companies. The
reasons for this are to ensure valid pieces of advice and recommendations on ener-
gy savings given to the building owner as well as high quality of the Energy Perfor-
mance Certificate. The objective of the regulation is energy saving measures.
New situation/ actions
11
Ministerial Order no. 1176 of 13 October 2015
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In October 2015, a new education as energy consultant was launched. The new
education has increased and sharpened the required entrance qualifications. In
order to be admitted to the education, one must have a relevant education ranging
at high school level and at a minimum two years of relevant work experience. Fur-
thermore, certified consultants must pass a refreshing course and exam every third
year in order to uphold their certificate. The initiative was passed in order to in-
crease the quality in the energy reports.
Time frame
Besides the introduction of the new education as energy consultant in October
2015, no further actions are foreseen.
Surveyor (DA – Landinspektør)
Competent authority: Danish Geodata Agency
Cluster category: Business services
Type of action: 1+2 (expected)
Current situation
The profession is regulated by reserves of activities for authorised land surveyors
which include, among other things, performing subdivision of real property and
other cadastral activities, including division of a building into condominiums. The
legislation governing the regulation of the profession is the Land Surveyors Act cf.
Consolidation Act no. 680 of 17 June 2013 and the Ministerial Order on the licens-
ing of authorised surveyors, the obligation to register for temporary provision of
services and disclosure obligations for chartered surveyors
12
.
In order to qualify for a Danish authorisation, the requirements are normally a
university degree (masters) as a land surveyor, plus three years of work experience
under the supervision of a chartered surveyor. The work must be connected to ca-
dastral work in order to fulfill the requirements, for example parcel subdivision,
change of property boundaries or the division of a building into condominiums.
Furthermore, the applicant must be legally competent and financially solvent in
order to qualify for an authorisation as a land surveyor.
The objectives with the regulation is to ensure a high level of quality in the services
supplied by authorised land surveyors, the independence of the chartered land
surveyor, the trust in the validity of the data of the Danish Cadastre, and the safety
for mortgagees and neighbours. Thus, the main reason for regulating the profes-
sion is that the Danish Cadastre is the basis for management of real property –
both in relation to private rights and public administration, taxation, Land Regis-
ter, mortgages, planning etc.
New situation/ actions
The Danish Geodata Agency has participated in the screening process in relation to
barriers for competition and growth. The objective was to conduct a study to inves-
tigate whether the restrictions on ownership of land surveying companies (includ-
12
Danish Agency for Higher
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Ministerial Order no. 703 of 17 June 2013
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ing rules on percentage of board members/ board of directors who must be author-
ised land surveyors) can be reformed while still maintaining the trust in the Danish
Cadastre and the administration that flows from it. As part of this on-going screen-
ing, the transfer of credits in order to obtain a degree in Land Management as a
basis for license as an authorised land surveyor is being examined as a possible
development.
Based on the results of the screening process, a change to the ownership re-
strictions for land surveying companies has been suggested in the present Danish
Government’s Growth Initiative (Vækst i hele Danmark 2015). The initiative will
increase competition, allow all companies to perform cadastral work and at the
same time maintain the independence of land surveyors, the quality of cadastral
work and the protection of consumers, recipients of services as well as other stake-
holders. The demand for professional liability insurance as well as the rules regard-
ing good conduct will be upheld.
Time frame
Legislation is being prepared. The initiatives are expected during 2016.
Danish Agency for Higher
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Trikinseeker (DA - Trikinsøger)
Current situation
Competent authority: The Danish Veterinary and Food Administration
Cluster category: Technical testing and analysis
Type of action: 5
The profession is regulated by reserves of activities which consist of conducting
analysis of and inspections for trichinella. According to the Commission Imple-
menting regulation (EU) 2015/1375 of 10 August 2015, which sets specific rules on
official controls for trichinella in meat, and Ministerial order No. 544 of 28 May
2014, a relevant education as trichinella seeker is required to get access to the pro-
fession.
To work as a trichinella seeker in Denmark, one has to be approved by an official
veterinarian and work under the official veterinarian's supervision and responsibil-
ity. Furthermore, one has to have completed and passed a course that is approved
by the Danish Veterinary and Food Administration (DVFA) and passed the final
exam as described in annex I, section III, chapter III, part B in regulation (EC) no
854/2004 of the European Parliament and of the Council of 29 April 2004 laying
down specific rules for the organisation of official controls on products of animal
origin intended for human consumption.
As analysing meat for trichinella requires knowledge of the technical requirements
and the relevant legal framework as well as experience in identifying trichinella
larvae in meat, the requirement of a certain degree of professional requirements is
considered to be justified.
There are four measures that a potential trichinella seeker has to abide by: 1. ap-
proval by an official veterinarian to work as a trichinella seeker, 2. work under the
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supervision and responsibility of an official veterinarian, 3. complete a course that
is approved by DVFA, and 4. pass the final exam as described in annex I, section
III, chapter III, part B in regulation (EC) no 854/2004 of the European Parliament
and of the Council of 29 April 2004 laying down specific rules for the organisation
of official controls on products of animal origin intended for human consumption
The four measures all work together to maximise food safety. As the wrongful han-
dling of trichinella susceptible meat can result in a serious risk to food safety, it is
important that a prospective trichinella seeker has been approved by an official
veterinarian and works under his/her supervision and responsibility. The test
which has to be completed and passed also helps ensure that the prospective trichi-
nella seeker possesses the right level of professional qualifications needed.
New situation/ actions
There are no actions foreseen since the system is working as intended.
Danish Agency for Higher
Education
Measurement and control technologist (DA – Certificeret Støjmåler)
Competent authority: The Danish Environmental Protection Agency
Cluster category: Business services
Type of action: 2 (decided)
Current situation
The profession is regulated by reserves of activities. The certification of individuals
for Environmental Noise Measurements and Noise Calculations is required in or-
der for the measurement and control technologist in question to carry out meas-
urements and calculations which are to be used in the Danish authorities’ adminis-
trative procedures. The purpose of the certification is to safeguard the quality, con-
sistency and impartiality of the basis for decisions made by the authorities as well
as to maintain the trustworthiness of the Environmental Noise Measurement and
Noise Calculation. Furthermore, the nature and the mathematics of Environmental
Noise Measurement and Noise Calculation require a technical background and
experience of sound propagation which is achieved through training and mainte-
nance of knowledge. The certification system ensures that this quality and con-
sistency is maintained.
In order to get access to the profession, i.e. acquire the certification, the person in
question must have a general or vocational post-secondary education equivalent to
M.Sc. in acoustics obtained from a Technical University. More specifically, the Min-
isterial Order on Quality Requirements for Environmental Measurements
13
lay
down the necessary prerequisites for the certification: A technical background and
experience of sound propagation which is achieved through training and mainte-
nance of knowledge.
New situation/actions
In 2014, it became possible for professionals who have had a valid certificate for
two consecutive periods of three years without annotations to renew the certificate
when the person has completed at least 2 “Environmental Noise Measurement” per
year over the previous 3 years.
13
Ministerial
Order no. 1311 of 15 November 2015
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Since recent improvements have taken place, no further actions are foreseen at the
moment. Furthermore, no actions or amendments have been proposed by the
stakeholders representing the following: FRI (the Danish Association of Consulting
Engineers), KL (Local Government Denmark), the certified persons (Measurement
and control technologist) and the Danish Environmental Protection Agency.
Time frame
Since new action took place in 2014, no further action if foreseen at the moment.
Translator and interpreter (DA – translatør og tolk)
Competent authority: The Danish Business Authority (DA – Erhvervsstyrelsen)
Cluster category: Business services
Type of action: 1 (decided)
Current situation
The profession is regulated by a protected title (without reserved activities). The
authorisation is given if the applicant meets the given educational requirements
14
.
The educational requirements depend on which language the applicant wants to be
authorised in
15
. The regulation only considers translation and interpretation from
and to Danish language. However, the authorisation does not give exclusive rights
to the translators besides the confirmed translations and the protected title. The
recipients of translation services can therefore choose to use translators and inter-
preterswithout authorisation.
The objective with the regulation is protection of consumers and recipients of ser-
vice. The requirements ensure that translators have the necessary qualifications to
maintain a high level of linguistic quality. This should be seen in the light of the fact
that translators are used in courtrooms and to make confirmed translations.
New situation/ actions
The Danish Parliament has passed an act which will abolish all regulation of the
profession. The act applies from 1 January 2016. The current system will be re-
moved without replacement. The reasons for abolishing the scheme are strength-
ened competitiveness, transparency for the consumers and simplification of rules
in general.
Time frame
The regulation regarding the profession will be abolished the 1th of January 2016.
Danish Agency for Higher
Education
Pig inseminator (DA – svineinseminør), Cattle inseminator (DA -
kvæginseminør), Furred animal inseminator (DA - pelsdyrsinsemiør)
and Horse inseminator (DA - hesteinseminør)
14
15
Articles 1 and 3 in the Act on Translator and Interpreter (lov om tranlatør og tolk)
Articles 3 in the Act on Translator and Interpreter (lov om translatør og tolk)
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Competent authority: The Danish Veterinary and Food Administration
Cluster category: Veterinary activities
Type of action: 2+3 (expected)
Current situation
There are four types of regulated inseminator professions. Each profession is regu-
lated by reserves of activities. Different requirements exist within the four profes-
sions:
Pig inseminator:
A course of one week’s duration, including a training peri-
od. There is a final written and oral exam
16
.
Cattle inseminator:
A basic course of 10 weeks’ duration, including a training peri-
od. There is a final written and oral exam. This is followed by a training period of 6
months and then a final approval course of 3 weeks. To be admitted to the course,
the applicant must at least be trained by a skilled farmer or the equivalent and have
been engaged in practical farming for at least one year
17
.
Furred animal inseminator:
A course of two weeks’ duration, including participa-
tion in a practical training period of one breeding season and passing of a
test/course of one day’s duration
18
.
Horse inseminator:
A basic course of 6 days’ duration with a final written and oral
exam. After that a subsequent follow-up course of one day’s duration
19
.
The objectives with the regulation are animal health and welfare.
New situation/ actions
The plan is that the legislation will be amended so that instead of receiving a permit
to inseminate from the Danish competent authorities, the attestation for complet-
ing the training course will be sufficient. Furthermore, a merger of legislation gov-
erning the conditions for entering the professions and the educational require-
ments to obtain the authorisation will take place. At the moment, each profession
has its own ministerial order and its own educational requirements. The plan is to
remove the current system and replace it with an alternative.
The Danish Veterinary and Food Administration will revise all orders on insemina-
tion into one order to harmonise administrative procedures. The service provider
will still need to complete a course for each animal species s/he wishes to insemi-
nate. The reason for the actions/deregulation is to lift the administrative burden of
economic operators. The service provider will not have to apply for approval as
inseminator as the diploma will serve as proof of authorisation to inseminate. In
the future, the training provider will have to forward information to the Danish
Veterinary and Food Administration on who has passed the course. In this way,
administrative burdens has been lifted of the service provider.
The actions consist of both change of administration/further digitalisation, merger
of schemes and less regulation.
Time frame
Order no. 598 of 29 June 1992 on boar semen
Order no. 1270 of 13 December 2004 on bull semen and insemination of cattle
18
Order no. 515 of 9 October 1984 on artificial insemination on fur animals
19
Order no. 83 of 27 January 2010 on insemination of equine
16
17
Danish Agency for Higher
Education
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The described changes will happen, but there is no specific time frame for the mo-
ment.
Authorised Veterinary Nurse (DA – Veterinærsygeplejerske)
Competent authority: The Danish Veterinary and Food Administration
Cluster category: Business services
Type of action: 1+4 (decided)
Current situation
The veterinary nurse profession is regulated by reserves of activities, and an au-
thorisation scheme is in place. Authorisation gives the veterinary nurse in question
the right to perform a number of tasks in a veterinary clinic under the responsibil-
ity of a veterinarian. The system is relatively new and is assessed to work as intend-
ed as it opens up the possibility for veterinary nurses to perform tasks that would
otherwise be preserved for veterinary surgeons. The specific tasks are described in
the Ministerial Order on Authorisation of Veterinary Nurses
20
. Authorisation can
be obtained if it can be documented that the veterinary nurse has completed the
education for veterinary nurse approved by the Ministry of Education or an educa-
tion that can be assessed as equivalent. The vocational education for veterinary
nurse takes 3,5 years and contains both theoretical and practical training.
The objectives with the regulation are protection of the consumer as well as animal
welfare. The requirements secure that the authorised veterinary nurse has the nec-
essary knowledge in order to perform the respective tasks.
New situation/ actions
Regulation regarding authorisation of veterinary nurses was introduced on 1 May
2011 with the purpose of expanding veterinary nurses’ access to perform additional
tasks in small animal clinics. Further regulation has taken place in October 2015.
Previously, some of the tasks in the Ministerial Order on Authorisation of Veteri-
nary Nurses
21
were reserved for the authorised veterinary nurse, while some of the
tasks could be performed by veterinary nurses without an authorisation as well. In
the new order on veterinary nurses, all tasks are reserved for authorised veterinary
nurses, who are given the possibility of performing additional tasks as well.
In the new order on veterinary nurses, the requirement that a veterinarian must
certify one's skills in terms of intravenous treatments before obtaining an authori-
sation is cancelled, and the authorisation can now be achieved solely on the basis of
completed education. In addition, the regulation has been amended so that a veter-
inary nurse now can obtain authorisation for either companion animal or horses,
depending on the specialisation she/he has completed her education within.
Time frame
The regulation was amended in October 2015, and no further actions are planned.
Danish Agency for Higher
Education
20
21
Ministerial Order no. 1153 of 30 October 2015
Ministerial Order no. 1153 of 30 October 2015
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Veterinary Technician (DA – veterinærtekniker)
Competent authority: The Danish Veterinary and Food Administration
Cluster category: Veterinary activities
Type of action: 5
Current situation
The profession is regulated by reserves of activities.
Veterinarians can, partly as part of a specific plan for disease or disease control
concerning diseases that are not covered by the Annexes to the Act on the keeping
of animals
22
, and partly as part of a decent control, be assisted by veterinary techni-
cians with regard to taking diagnostic tests of cattle, pigs, horses, sheep, goats, fur
animals and poultry for study at the National Veterinary Institute or a laboratory
approved by The Danish Veterinary and Food Administration.
Authorisation as a veterinary technician can be given to a person who is operating
under a named veterinarian’s management and responsibility and who has received
training in several specific subjects. There is no requirement for the teaching peri-
od, but only for a number of issues which should been taught. The authorisation as
a veterinary technician is linked to employment and expires upon termination of
employment.
The objectives with the regulation are protection of the animal welfare and animal
health.
The requirements secure that the authorised veterinary technician has the neces-
sary knowledge in order to perform the respective tasks.
New situation/ actions
There has not been taken any actions recently in order to amend the regulation.
An amendment of the regulation is under consideration in order to meet national
needs for an update within the profession. There has not been made a decision
whether to follow through with the amendments and which form these will be in.
Danish Agency for Higher
Education
Veterinary Surgeon (DA – Dyrlæge)
Competent authority: The Danish Veterinary and Food Administration
Cluster category: Business services
Type of action: 5
Current situation
The profession is regulated by reserves of activities.
The profession is regulated by the Danish Veterinary Surgeon Act
23
and Ministerial
Order
24
on the access to the veterinary profession in Denmark for EU and EEA
citizens and citizens of a country with which the EU has an agreement on profes-
sional recognition, as amended by two Ministerial Orders
25
. The requirements in
Act no. 432 of 9 June 2004
Ministerial Order No. 1149 of 12 September 2015
24
No. 1176 of 11 October 2007
22
23
25
Ministerial Order No. 1328 of 15 December 2009 and Ministerial Order No. 931 of 5 July 2013.
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the Danish Veterinary Surgeon Act secure that only persons with the necessary
education, skills and knowledge have the right to work as a veterinary surgeon.
In order to get access to the profession, the person in question must have obtained
a diploma from the University of Copenhagen (candidate in veterinary medicine -
Cand. Med. Vet.) or a similar education from another EU member state meeting the
minimum training requirements set out in Article 38 and Annex 5.4.1. of Directive
2005/36/EC. An authorisation as veterinary surgeon gives the right to work as a
veterinary surgeon (and to use the title "veterinary surgeon") and to perform the
veterinary tasks with regard to animals as regulated by the Danish Veterinary Sur-
geon Act.
The objectives with the regulation are animal health, animal welfare and consumer
protection.
New situation/ actions
No actions are planned within this profession since the system is working as in-
tended. The Danish Veterinary Surgeon Act lays down all the necessary require-
ments for sound performance of the task as veterinary surgeon.
Danish Agency for Higher
Education
Worker in mink farms (DA - erhverv i pelsfarme)
Competent authority: The Danish Veterinary and Food Administration
Cluster category: Business Services
Type of action: 5
Current situation
The profession is regulated by reserves of activities. The regulation concerns per-
sons working in mink farms and persons supervising the killing of fur animals on
fur farms
26
. With regard to persons supervising the killing of fur animals on fur
farms, these requirements are based on Council Regulation (EC) No 1099/2009 of
24 September 2009 on the protection of animals at the time of killing.
Persons in charge of the keeping of mink on a fur farm must have completed an
education fulfilling requirements mentioned in the Ministerial Order
27
. The educa-
tion consists of a theoretical part (minimum 32 hours) and a practical part (mini-
mum 148 hours). The education must be completed within 1 year after the person
has assumed responsibility for the breeding.
Persons who are occupied with the handling of live mink must have completed a
course of minimum 8 hours fulfilling the requirements mentioned in the Ministeri-
al Order. The course must be completed within 4 weeks after the employment is
commenced.
The objectives with the regulation are animal health and animal welfare.
New situation/ actions
26
27
Ministerial Order no. 1207 of 14 December 2007
Ministerial Order no. 1207 of 14 December 2007
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The Ministerial Order
28
lays down all the necessary requirements for the sound
performance of the professions regulated by the Ministerial Order with the aim of
securing animal health and animal welfare. No actions are planned within this pro-
fession since the system is working as intended.
Implantation of transponders in equidae (DA – ID-mærkere af dyr af
hestefamilien)
Competent authority: The Danish Veterinary and Food Administration
Cluster category: Veterinary activities
Type of action: 5
Current situation
The profession is regulated by reserved activities. In order to get access to the pro-
fession, a 5 days’ course approved by the Danish Veterinary and Food Administra-
tion is required. The courses are currently provided by SEGES. The course consists
of theoretic and practical training that makes the participants able to implant tran-
sponders in equidae. The objective with the regulation is animal welfare.
New situation/ actions
The requirements regarding the content of the course has been described in greater
detail in a new Ministerial Order
29
on identification of equidae which will come into
force on 1 January 2016. The new order replaces the Ministerial Order on Identifi-
cation of Equidae
30
. The aim is to support the welfare of horses. It does not affect
the individual who exercises the profession but only the course providers.
Danish Agency for Higher
Education
Security guard/ Warden (DA – vagtvirksomhed)
Competent authority: Ministry of Justice
Cluster category: Business services
Type of action: 2 (decided)
Current situation
The profession is regulated by reserves of activities and described in the Consolida-
tion Act on Security Services and the order on Security Services
31
. Security guards
perform various guarding and security tasks, e.g. monitoring in malls, monitoring
the area of a private company or controlling the access to a private or public build-
ing. The work of security companies contributes to crime prevention.
Both companies offering security guard services and independent security guards
must obtain an authorisation by the Danish police. In order to get an authorisation,
the applicant must, among others, have turned 25 years old and not have a consid-
erable debt to the public sector. Furthermore, the applicant must not have been
Ministerial Order no. 1207 of 14 December 2007
Ministerial Order no. 1398 of 2 December 2015
30
Ministerial Order no. 1448 of 15 December 2009
31
Consolidated Act no. 227 of 3 March 2010 with later changes and Order no. 1045 of 30 September
2014.
28
29
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convicted of a crime that causes a reasonable risk of abuse of the position and gives
reason to assume that the applicant will not be able to practice the position in a
proper manner and in accordance with good practices within the sector. In addi-
tion, employees need an approval. In order to get an approval, the applicant must
have completed one of the following: a specific education for security guards, a
similar education through a specific education for bodyguards or have similar qual-
ifications which can be recognised after the rules of the directive on the recognition
of professional qualifications. Approval can be denied if, for instance, the applicant
is convicted of a crime and the circumstances of the conviction cause a reasonable
risk of abuse of the position.
The objectives with the regulation are public security: it is necessary to make sure
that the work of security guards is exercised in a proper and safe way and that the
security guards are not acting in a way that can be interpreted as private police
forces. Moreover, security guards often get access to private areas in a way that
involves a risk of illegal activities such as stealing and industrial espionage, and
security guards should therefore be governed by regulation.
New situation/ actions
In order to strengthen the regulation of security guards in Denmark, the Ministry
of Justice in January 2009 requested the Danish National Police to establish a
working group for the revision of the regulatory rules that apply to the profession.
The working group, which consisted of various interested parties from the security
service industry, including both employers' associations and trade unions, and the
National Police, issued a report in October 2009. Based on the working group's
suggestions, the Minister of Justice has amended Order no. 1564 of 20 December
2007. The amendment involves specifying which information that needs to accom-
pany an application for authorisation to carry out commercial security services, the
National Police’s opportunity to lay down conditions regarding reporting on com-
pany conditions and a requirement regarding security guards’ obligation to carry
personal identification cards visible.
The amendment has also changed the rules regarding temporary staff. Temporary
staff can now be engaged for office duty in security companies. Furthermore, the
National Police has elaborated guidelines for administration of applications for
authorisation and approval in order to ensure a uniform practice. Order no. 1564
of 20 December 2007 has been superseded by order no. 1045 of 30 September
2014.
Time frame
Since order no. 10415 of 30 September 2014 has been changed no further actions
has been taken.
Danish Agency for Higher
Education
Security guard/ warden (DA – Autoriseret kontrollør ved bestemte
idrætsbegivenheder)
Competent authority: Ministry of Justice (Danish National Police)
Cluster category: Business services
Type of action: 4 (decided)
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Current situation
According to Act on Security at Certain Sports Events
32
and Order on Security at
Certain Sports Events
33
, it is required that security inspectors at certain sports
events have an authorisation. The requirements consist of a 3 days course (the
Gateman education by the Danish Football Association). The objectives of the regu-
lation are public security.
The purpose of Act on Security at Certain Sports Events
34
and Order on Security at
Certain Sports Events
35
is to ensure that the police and the football clubs have the
necessary tools in order to prevent violence and riots at specific football matches.
The purpose of the regulation specifically regarding the security inspectors is to
ensure that the security inspectors have the adequate knowledge on handling per-
sonally sensitive information and to ensure that the enforcement of the quarantines
is done effectively and consistently.
Authorisation can be given to an applicant who has qualifications which can be
recognised after the rules of the directive on the recognition of professional qualifi-
cations and if the applicant meets the mentioned requirements.
New situation/ actions
The regulation was evaluated in 2011-2012. Due to security reasons, there is still a
need to demand that persons who work as security inspectors at certain sports
events have completed an education for inspectors. This ensures an equal high level
of expertise among the inspectors. In 2013, the regulation was amended in order to
ensure that dispensation from the education criteria is only given when the appli-
cant without doubt is qualified.
In 2015, the Act on Security at Certain Sports Events
36
was replaced by Consolidat-
ed Act on Security at Certain Sports Events
37
.
Danish Agency for Higher
Education
Doorman (DA - dørmand i virksomheder med alkoholbevilling)
Competent authority: The Danish Business Authority
Cluster category: Business Services
Type of action: 5
Current situation
The profession is regulated by reserves of activities. These activities consists of
checking guests wishing to enter the licensed establishment, monitoring the li-
censed establishment in order to prevent violent situations, intervening in violent
situations and detaining the offender until the police arrives.
The education as a doorman can be obtained by receiving adult vocational training,
so called AMU. There are no specific admission requirements to this and the course
Act no. 307 of 30 April 2008
Order no. 650 of 26 June 2008
34
Act no. 307 of 30 April 2008
35
Order no. 650 of 26 June 2008
36
Act no. 307 of 30 April 2008
37
Consolidated Act no. 1216 of 27 October 2015
32
33
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lasts 8 days. On the basis of the certificate for a passed test, the participant can
apply for authorisation at the police. Authorisation is issued after a satisfactory
background check in police records, and the applicant will receive a personal iden-
tification card issued by The National Police. This is regulated in the Ministerial
Order on Doormen
38
. This card shall be carried when performing the reserved ac-
tivities. The objective of the regulation is public security.
The rules regarding a doorman’s mandatory education and authorisation emerged
as a consequence of the Government’s fight against drugs in the night life (the ac-
tion plan “Kampen mod narko” from October 2003).The education safeguards the
doorman’s knowledge regarding service, communication, cooperation, conflict
management, drugs, first aid, firefighting and the existing laws on the field of
doormen. Great emphasis is placed on the ability to recognise drug dealing and
people who are under the influence of drugs. The education required for an author-
isation as a doorman contributes to the protection of public security, and in partic-
ular the security of customers in the night life.
New situation/ actions
In 2013, the profession was examined by a governmental task force (established as
a part of the Government’s competitiveness policy package from 2012) in order to
identify simplification potential. The taskforce has not resulted in any changes
regarding the authorisation of doormen in businesses with liquor license. The edu-
cation is continually up-to-date evaluated.
Danish Agency for Higher
Education
Chimney sweep (DA - skorstensfejer)
Competent authority: the Danish Transport and Construction Agency
Cluster category: Business services
Type of Action: 5
Current situation
The profession is regulated by reserves of activities and protected title.
The regulation of the chimney sweep profession consists of educational require-
ments.
39
More specifically, the education is a 4,5 year vocational education This
means that the chimney sweep must have an education in sweeping chimneys or
similar skills from other relevant education
40
. The purpose of the regulation is to
ensure fire safety in buildings and houses to avoid serious damage to health and
safety. It is therefore necessary to have the possibility of checking the professional
qualifications of the chimney sweep prior to the first provision of services to ensure
that the chimney sweep is qualified to clean chimneys and can ensure fire preven-
tive supervision of the chimneys.
The consequence of improper sweeping of a chimney can result fire in the chimney
and the building.
Ministerial Order no. 247 of 11 April 2008
Regulation 239 of 27 April 1993 with amendments
40
Ministerial Order no. 239 of 27 April 1993, as amended. Execute Order no. 1308 of 23 November
2007 Ministerial Order no. 1335 of 15 December 2009.
38
39
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New situation/ actions
The regulation is for the time under revision. The purpose of the revision is a clari-
fication of the existing regulation However, this will not change the requirements to
the competences that the chimney sweep must have. It is expected that the revision
of the regulation has an effective date of 1 July, 2016.
The regulation contines to ensure fire safety and to ensure the fire preventive su-
pervision of the chimneys. The chimney sweep has a central role to ensure this
supervision in cooperation with the local municipality.
Rat controller (DA - Rottebekæmpelse)
Competent authority: The Danish Nature Agency
Cluster category: Business services
Type of action: 2 (expected)
Current situation
The profession is regulated by reserves of activities. In order to become an author-
ised rat controller, it is mandatory to complete a rat controller authorisation course
along with an aptitude test. Before enrolling in the course and taking the aptitude
test, 3-6 months related professional training is a amandatory requirement.
The current legislation is from 2012. It was considered to remove the requirement
for rat controllers to participate in the authorisation course and condition the au-
thorisation on the aptitude test alone – but it was decided not to. Since the regula-
tion is rather new, no alternative approaches to regulate the rat controller profes-
sion has been considered so far.
The authorisation gives the right to carry out rat extermination including utilisa-
tion of rodenticides. The objective of the regulation is to make sure that rat control
is handled in a professional and skilled manner. Improper or inadequate handling
of rodenticides can result in serious safety and health problems for people, direct
and indirect poisoning of other animals and thus be a threat to the biodiversity of
the surrounding area.
The requirements make sure that rat controllers practicing in Denmark have the
necessary qualifications to make decisions based on qualified and educated
grounds and that the person in question knows how to act correctly according to
the relevant national legislation.
New situation/ actions
In 2016, the current regulation will be updated in order to correspond to the re-
vised directive (2013/55/EU). The Danish Nature Agency is furthermore contem-
plating a revision of the regulation.
Time frame
The revision of the regulation is expected, but there is no specific timeframe at the
moment.
Danish Agency for Higher
Education
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Vermin controller (Persons using gas for vermin control must be li-
censed)/ (DA – Skadedyrsbekæmper (desinfektør)
Competent authority: The Danish Environmental Protection Agency
Cluster category: Wholesale and retail
Type of action: 2+4 (expected)
Current situation
The profession is regulated by reserves of activities. In order to perform the activi-
ties, the person in question needs to obtain a certificate by completing 10 days of
training (74 hours) (for limited activity: 2 days/ 12 hours). The objectives with the
regulation are public health and protection of the environment.
New situation/actions
Change to the regulation is planned in early 2016 (delayed from November 2015).
The change concerns more digitalisation of an authorisation scheme and more
control related to the reserved activities.
Time frame
Change of regulation expected to take place early 2016.
Danish Agency for Higher
Education
Cluster 1 - CONSTRUCTION
Certified Building Expert (DA – beskikket bygningssagkyndig)
Competent authority: the Danish Business Authority
Cluster category: Construction
Type of action: 1+2 (decided)
Current situation
The profession is regulated by reserves of activities. According
to the Act on Certi-
fied Building Experts
41
, only building experts are authorised to prepare a report on
house conditions. The report describes visible faults with and defects of the proper-
ty and makes basis for a change of ownership insurance.
The building experts are part of the house inspection scheme which concerns the
purchase and sale of properties primarily used as dwellings. The purpose of the
scheme is to ensure that a seller is released from their 10-year liability to the buyer
for hidden faults and defects by producing a valid house condition report as well as
information on change of ownership insurance before the purchase agreement is
signed.
In order to obtain the authorisation, the building experts must
fulfill certain re-
quirements regarding, among other things, education, work experience and insur-
ance according to the Ministerial Order on the House Inspection System
42
. The
authorisation expires after 3 years, and then, the authorisation must be renewed.
41
42
Act no. 1532 of 21 December 2010
Ministerial Order no. 60 of 21 January 2015
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The objective with the regulation is protection of consumers and recipients of ser-
vices. Buying a real property is the largest economic disposition in a consumer’s
life.
New situation/ actions
Since establishing the scheme, it has been evaluated several times. The latest evalu-
ations took place in 2010 by a committee under the Danish Ministry of Justice and
in 2014 by the Danish Government’s task force for regulated professions mentioned
earlier. The recommendations of the committee were implemented in May 2012.
The task force recommendations will be implemented in January 2016, including
abolishment of the rules concerning the building experts’ maximum price for a
report. Furthermore, digitalisation of the building experts work will be implement-
ed to make the scheme more effective.
Time frame
The changes will happen in January 2016
Danish Agency for Higher
Education
Work as boiler attendant (Work with maintenance of hot water and
steam boilers) (DA – Arbejde som kedelpasser)), Work with erection of
scaffolding (DA – Arbejde med opstilling af stilladser), Work with
asphalt materials (DA – Arbejde med asfaltmaterialer), Work with
epoxy and isocyanates (DA – Arbejde med epoxy og isocyanater),
Work with a telescope loader (DA – Arbejde med teleskoplæsser),
Work with welding (Work with welding and thermic cutting in met-
als) (DA – Arbejde med svejsning)Work with asbestos (DA – arbejde
med asbest), Work with styrene (DA – arbejde med styrene), Work as
refrigeration engineer (work with refrigeration plants and heat
pumps) (DA – kølemontør), Forklift driver (Work with forklift truck)
(DA – gaffeltruckfører), Work with forklift trucks (DA – gaffelstabler)
and Health and safety coordinator in the field of building and con-
struction (DA – koordinator for sikkerheds- og sundshedsarbejdet på
bygge- og anlægsområdet).
Competent
authority:
the
Cluster category: Construction
Type of action: 5
Danish
Working
Environment
Authority
Current situation
Each of the above mentioned professions has the same key characteristics in rela-
tion to regulation, objectives and foreseen actions. All of the covered professions
are regulated by reserves of activities. The educational requirement for each of the
12 professions is a short health and safety course. The objective of the course is to
ensure sufficient qualifications regarding health and safety in order to prevent risks
during work for both the employee and others. The main objective of the regulation
is public security and health.
New situation/ actions
There are currently no planned changes to the health and safety courses for any of
the professions. The 12 professions are all associated with significant health and
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safety risks, and it is therefore important to be able to react properly in any high-
risk situation that may endanger the health and safety of the personnel and to know
the proper emergency response function. The requirements of each regulated pro-
fession seek to minimise the health and safety risks associated with the individual
jobs.
Structural Engineer (DA – Anerkendt statiker)
Competent authority: the Danish Society of Engineers (IDA) (authorised by the
Danish Transport and Construction Agency
43
)
Cluster category: Construction
Type of action: 2 (expected)
Current situation
The profession is regulated by reserves of activities. The regulation of structural
engineering is based on a recognition system which means that structural engineers
must be certified in accordance with the Buildings Regulations. The system is fur-
thermore designed to facilitate the work of authorities reducing processing time
when handling building projects without reducing projects static documentation.
Certification can be issued to engineers with one of the following Danish degrees:
Master of Science in Engineering (M.Sc.(Eng.)), Bachelor of Science in Engineering
with honours (B.Sc.Eng.(Hons.)) or Bachelor of Science in Engineer-
ing(BSc.(Eng.)).
Applicants who do not have any of the above mentioned degrees have the oppor-
tunity to take a test or examination to ascertain whether they have the requisite
professional expertise. Furthermore, details of the applicant’s work history in a
given period leading up to the application are required for certification.
Furthermore, engineers who have evidence of competence, academic qualification
or a certificate which in another country authorises them to practice structural
engineering in that country may practice as certified structural engineers in Den-
mark provided that the qualification or certificate has been issued by a competent
authority in the country in question
44
.
The purpose with the regulation is to prevent failures in buildings that are classi-
fied in high consequence class and where failures seriously will endanger human
life. It is therefore necessary to have the possibility to check the professional quali-
fications of the structural engineer prior to the first provision of services to ensure
health and safety. The consequence of improper structural documentation can be
failures of the load-bearing structures and endanger human life.
Danish Agency for Higher
Education
New situation/actions
In November 2015, the Danish Government presented a new policy package (Vækst
og udvikling i hele Danmark). According to the package, the system of recognition
for structural engineers will be modernised by introducing a certification system
that is more comprehensive and flexible than the existing onerous one. It is ex-
pected that the revision of the system will reduce existing barriers and make it easi-
er to access the profession as a structural engineer.
43
44
Buildings Regulations, Appendix 3
Buildings Regulations, Appendix 3, 4.2
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Time frame
For the moment there is no specific time frame for the revision of the system. It is
expected that the Buildings Regulations will be revised during 2016 in order to
amend the system.
Well driller (DA - Brøndborer)
Competent authority: The Danish Nature Agency
Cluster category: Construction
Type of action: 2 (decided)
Current situation
The profession is regulated by reserves of activities based on a statutory order Nr.
1826 by 16/12/2015 about education of well drillers on land which lays down the
educational requirements. These consist of an education with specific requirements
lasting at least 28 days. The education gives the right to carry out well drilling. The
objective with the regulation is protection of environment and groundwater, as
inappropriate and careless behavior can harm the groundwater/ drinking water
and thus public health. The requirements make sure that a well driller has the nec-
essary qualifications to make well drilling.
New situation/ actions
The Danish Nature Agency is currently modernising the education to keep up with
the technological development in the field. The ongoing modernisation, among
other things, keeps up with the technological development in the field. The mod-
ernisation of the education will not make compromises in regard to the health and
environmental protection concerns or inhibit a practical enforcement of the rules.
Time table
The modernisation is carried out during the course of 2015 and will enter into force
in the beginning of 2016.
Danish Agency for Higher
Education
Commercial diver (DA - Erhvervsdykker)
Competent authority: The Danish Maritime Authority
Cluster category: Construction
Type of action: 5
Current situation
The profession is regulated by reserves of activities. In order to perform the activi-
ties in Denmark, authorisation by the Danish Maritime Authority is required. There
is no application form, instead, the person in question must write a letter stating
his/ her profession and explain his/ her wish to work as a commercial driver on a
permanent basis. Authorisation is given to those who, among other things, can
provide proof of professional experience, e.g. pay slips or attestations from employ-
ers identifying the professional activity and its duration (if any) and a medical apti-
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tude certificate. If the person in question is from a Member State which does not
regulate the profession, proof of having practiced the profession for at least two
years in the last ten years in the Member State of establishment is required. The
profession is regulated in the Consolidation Act on Diving Works and Diving Mate-
rials
45
.
The objectives of the regulation are to ensumre the life and health of persons using
diving equipment in Danish waters and to promote the health and safety conditions
for the persons performing diving operation.
The protection of the profession has been introduced to take account of the consid-
erable poorer visibility in Danish waters than in, for example, the Mediterranean,
as well as of the complexity of the profession when performed in Danish waters.
New situation/ actions
No actions are planned.
Danish Agency for Higher
Education
Electrical, gas, plumbing and sewer fields (DA – El-, gas-, vvs- og
kloakområdet)
The professions described in the following are electrical contractor (DA – elinstal-
latør), gas, plumbing and sanitation fitter (DA – gas-, vand- og sanitetsmester) and
sewage contractor (DA – kloakmester). At first, these professions will be described
individually, and then a joint description of actions taken to liberalise the regula-
tions will follow.
Electrical Contractor (DA - Elinstallatør)
Competent authority: Danish Safety Technology Authority
Cluster category: construction
Type of action: 1+2+3 (decided)
Current situation
This profession is regulated by reserves of activities. The profession is part of the
single company authorisation scheme for professionals in the electrical, gas,
plumbing and sewer sector, which was introduced by law in June 2014 (the author-
isation scheme is elaborated in the following section, i.e. “New situation/ actions”).
The overall purpose of the authorisation agreement in the electrical field is to en-
sure that companies carrying out electrical work are competent. In the electrical
field, there is direct connection between the competence of the companies and the
risk of electrical accidents/injuries and electrical fires. For the sake of the safety
and protection of the consumers and the performing workers, the installation work
carried out must therefore be of high quality.
The Danish Safety Technology Authority can approve a person as technically re-
sponsible when the person can prove that he/she has passed a qualifying test with-
in the relevant field. The requirements of education and qualifying tests are speci-
fied in the Ministerial Order on Approval of Technical Responsible Persons within
45
Consolidation Act no. 69 of 17 January 2014 cf. chapter 2 paragraphs 6-11.
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the Electrical, Gas, Plumbing and Sewer fields
46
.Furthermore, the applicant must
be of legal age and must not be under guardianship.
The company which applies for authorisation or sub-authorisation must have the
right competences – i.e. a technically responsible person within the authorisation
field.
New situation/ actions
Denmark has undertaken measures to liberalise the regulation of professions in the
electrical, gas, plumbing and sewer fields. This area was characterised by different
types of authorisation schemes depending on whether the person in question was
working with electricity, gas, plumbing or sewers, creating a complex system for
both companies and restricting the freedom of professionals to work across the
sector.
There was a demand for modernising the system, and consequently, a single com-
pany authorisation scheme was introduced for professionals in the electrical, gas,
plumbing and sewer sector. This meant that it became possible for the company to
have full responsibility for the performance of work while maintaining a high level
of security, i.e. through an approved self-certification system. This was done by
altering the existing personal authorisation and the special personal criminal liabil-
ity in the electrical area. Instead the company as a whole gets increased responsibil-
ity but also more flexibility. It also provides greater flexibility to the professional to
work in a range of disciplines under one regulatory system. However, there must be
at least one technically responsible person affiliated with the company for a mini-
mum of 30 hours a week within business hours, the person’s professional skills
must be approved by the Danish Safety Technology Authority, and a company must
have an approved quality management system.
In addition, as an alternative to ‘full’ authorisation, a part-authorisation scheme for
electrical contractors, gas fitters and plumbers was also introduced in order to
make more companies and professionals able to perform all parts of a task for the
consumer. The purpose of this was also to make it possible for the companies with-
out former authorisation to get new and more flexible options for ongoing qualifi-
cation and thereby create new markets and increased growth.
The new authorisation scheme is more flexible for the companies, but it also places
the responsibility of having the right competencies regarding installations with the
company. The changes were adopted by the Danish Parliament in April 2014, and
the Act on Authorisation of Companies in the Electrical, Gas, Plumbing and Sewer
Fields
47
entered into force in June 2014.
Since the Act on Authorisation of Companies in the Electrical, Gas, Plumbing and
Sewer Fields
48
, new educations in the part-authorisation fields for electrical con-
tractors, and plumbing contractors have been established.
Danish Agency for Higher
Education
Order no. 543 of 22 May 2014
no. 401 of 28 April 2014
48
Act no. 401 of 28 April 2014
47
Act
46
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Gas, Plumbing and Sanitation Fitter (DA - Gas-, vand- og sanitetsme-
ster (vvs-installatør)
Competent authority: Danish Safety Technology Authority
Cluster category: Construction
Type of action: 1+2+3 (decided)
Current situation
The profession is regulated by reserves of activities. The profession is part of the
single company authorisation scheme for professionals in the electrical, gas,
plumbing and sewer sector
49
, which was described in further details in the above
description of electrical contractor – “New situation/ actions”. The objective with
the regulation is protection of consumers and recipients of service as well as the
persons carrying out gas-installations.
Authorisation entitles the company in question to carry out and service water in-
stallations and drainage installations above ground level and in buildings and also
gas installations using town gas, natural gas, bottled gas, biogas, hydrogen or simi-
lar flammable gases. The authorisation of a company ensures that installations are
carried out and serviced correctly for the sake of health, safety and the environ-
ment. The Act on Authorisation of Companies in the Electrical, Gas, Plumbing and
Sewer Fields
50
legislation regulates which types of installation work require author-
isation – and which can be carried out without authorisation. In order to obtain
authorisation, at least one technically responsible person must be affiliated with the
company for a minimum of 30 hours a week within normal business hours cf. Act
on Authorisation of Companies in the Electrical, Gas, Plumbing and Sewer Fields
51
.
The person’s professional skills must be approved by the Danish Safety Technology
Authority. The requirements of education and qualifying tests are specified in the
Ministerial Order on Approval of Technical Responsible Persons within the Electri-
cal, Gas, Plumbing and Sewer fields
52
.
New situation/ actions
No new actions have been taken since the implementation of the single company
authorisation scheme for professionals in the electrical, gas, plumbing and sewer
sector.
Sewage contractor (DA – kloakmester)
Competent authority: Danish Safety Technology Authority
Cluster category: Construction
Type of action: 1+2+3 (decided)
Current situation
The profession is regulated by reserves of activities. The profession is part of the
single company authorisation scheme for professionals in the electrical, gas,
plumbing and sewer sector
53
, which was described in further details in the above
description of electrical contractor – “New situation/ actions”
Danish Agency for Higher
Education
49
Act
50
Act
no. 401 of 28 April 2014
no. 401 of 28 April 2014
51
Act no. 401 of 28 April 2014
52
Ministerial Order no. 543 of 22 May 2014
53
Act no. 401 of 28 April 2014
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Authorisation entitles the company in question to carry out and repair sewage in-
stallations and drainage works in soil including penetration of floors, foundation or
outer wall against soil and the related sewage pipes. Authorisation ensures that
installations are carried out and repaired correctly for the sake of health, safety and
the environment. Thus, the objective with the regulation is protection of consumers
and recipients of service as well as protection of the environment and the urban
environment, including town and country planning. The Act on Authorisation of
Companies in the Electrical, Gas, Plumbing and Sewer Fields
54
regulates which
types of installation work require authorisation – and which can be carried out
without authorisation.
In order to obtain authorisation, at least one technically responsible person must
be affiliated with the company for a minimum of 30 hours a week within normal
business hours. The person’s professional skills must be approved by the Danish
Safety Technology Authority. The requirements of education and qualifying tests
are specified in the Ministerial Order on Approval of Technical Responsible Per-
sons within the Electrical, Gas, Plumbing and Sewer fields
55
.
Danish Agency for Higher
Education
New situation/ actions
No new actions have been taken since the implementation of the single company
authorisation scheme for professionals in the electrical, gas, plumbing and sewer
sector.
Lift inspection (DA – elevatoreftersyn)
Competent authority: the Danish Working Environment Authority
Cluster category: Construction
Type of action: 2 (expected)
Current situation
The profession is regulated by reserves of activities. The educational requirement is
a short health and safety course (10 days) as the profession is associated with
health and safety risks. The profession is regulated by the Ministerial Order on
Occupational Safety and Health Training annex 3
56
, and the requirement for train-
ing was introduced in Ministerial Order no. 509 of 18 June 2007 section 15. The
main objective of the course is to provide the knowledge necessary to perform the
job safely for the protection of the worker as well as others. The objective of the
regulation
in
general
is
public
security
and
health.
New situation/ actions
The Danish Working Environment Authority is considering implementing im-
provements to the health and safety course with the purpose of making a new and
simplified version of the education. The target group of the course will be trained
craftsmen who need to acquire skills of how to carry out tasks related to inspec-
tions, maintenance and repair work in a safe manner. The Danish Working Envi-
54
Act
no. 401 of 28 April 2014
Order no. 543 of 22 May 2014
56
Ministerial Order on occupational safety and health training no. 1088 of 28 November 2011
55
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ronment Authority will cooperate with the social partners in examining how the
changes may be implemented.
Time frame
Actions to improve the education are foreseen to take place during 2016-2017.
Work with mobile cranes and tower cranes (DA – arbejde med mobil-
og tårnkraner)
Competent
authority:
the
Cluster category: Construction
Type of action: 2+ 3 (expected)
Danish
Working
Environment
Authority
Danish Agency for Higher
Education
Current situation
The profession is regulated by reserves of activities. The educational requirement is
a short health and safety course as the profession is associated with health and
safety risks. The profession is regulated by the Ministerial Order on Occupational
Safety and Health Training annex 1
57
. The main objective of the course is to provide
the knowledge necessary to perform the job safely for the protection of the worker
as well as others.
Currently, six different types of crane certificates exist, each issued to operate a
specific type of crane.
New situation/actions
A simplification of the health and safety course has been suggested for the purpose
of aligning the education criteria with the specific needs of the profession. Fur-
thermore, the course should be more adapted to the challenges that the individual
crane driver faces. The aim of implementing a new version of the education is to
give crane drivers the ability to steer several different types of cranes thereby
achieving a broader access to the profession whilst taking the technological devel-
opment into account.
Time frame
Actions to improve the education are foreseen to take place during 2016-2017.
Offshore-professions (DA – arbejde på offshoreanlæg)
Competent authority: the Danish Working Environment Authority
Cluster category: Cluster 1 and Cluster 2.
Type of action: 1 +3 (decided)
Current situation
By the end of 2015 there were approximately 15 offshore professions/skills that
57
Ministerial Order on occupational safety and health training no. 1088 of 28 November 2011
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were regulated by reserves of activities. The educational requirements consist of
short health and safety courses.
New situation/actions
As regards work with biological agents, the Ministerial Order on protection from
exposure to biological agents on offshore installations
58
has been changed as per 1
January 2016. As regards instructor in safety and health work on offshore installa-
tions, the Ministerial Order on safety group safety training on offshore installations
was changed in the autumn 2015. With these adjustments, work within these areas
is no longer considered as regulated professions, bringing the total number of off-
shore professions that are categorised as regulated professions down with 2. Both
initiatives have been taken to unite regulation and the practicable handling of the
rules.
As regards well controller on offshore installations and the person responsible for
drilling operations offshore, the two professions have been merged and is now one
regulated offshore profession/skill instead of two. In the future, the profession is
called ‘responsible for drilling operations (well control course)’.
In the autumn 2015, other changes have taken place for some of the offshore-
professions as 6 offshore professions no longer are categorised as regulated profes-
sions. These are the following:
Fire Fighter on permanently manned installations (education in fire
fighting) (DA – Brandmand på permanent bemandet anlæg (uddannelse i
brandbekæmpelse)).
Fire Fighting Leader on permanently manned installations (education as
fire fighting leader) (DA – Brandslukningsleder på permanent bemandet
anlæg (uddannelse som brandleder)).
First Aider on permanently manned installations (first aid course) (DA –
Førstehjælper på permanent bemandet anlæg (førstehjælpskursus)).
Lifeboat Operator, etc. on permanently manned installations (education in
operating lifeboats etc.) (DA – Redningsbådsfører m.v. på permanent be-
mandet anlæg (uddannelse i betjening af redningsbåde m.v.)).
Work on installations (Basic safety training for all employees on installa-
tions, etc.) (DA – Arbejde på anlæg (grundlæggende sikkerhedsuddannelse
for alle ansatte på anlæg m.v.)).
Work with H2S or other dangerous substances and materials (education in
countering danger on these substances or materials) (DA – Arbejde med
H2S eller andre farlige stoffer og materialer (uddannelse i imødegåelse af
fare ved disse stoffer og materialer)).
With these changes, the total number of offshore professions that are categorised
as regulated professions is brought down to 8 with effect from January 2016.
Thus, per January 2016, only the following professions will be regulated:
Work with welding (education in welding works) (DA – Arbejde med svejs-
ning (uddannelse i svejsearbejde)).
Responsible for drilling operations (well control course) (DA – Ansvarlig
for boreoprationer).
Danish Agency for Higher
Education
Ministerial Order no. 1342 of 27 November 2015 on protection against exposing to biological agents in
connection with offshore oil and gas activities etc., section 6
58
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Work as crane driver on offshore installations etc. (crane driver certificate)
(DA – Arbejde som kranfører på anlæg m.v. (kranførercertifikat)).
Work as fork-lift truck driver and operator of fork-lift stacker on offshore
installations, etc. (fork-lift truck driver certificate) (DA – Arbejde som gaf-
feltruckfører samt fører af gaffelstabler på anlæg m.v. (gaffeltruckførercer-
tifikat)).
Work with asbestos (education in demolition on asbestos) (DA – Arbejde
med asbest (uddannelse i nedrivning af asbest)).
Work with epoxy and isocyanates on offshore installations, etc. (Epoxy-
education) (DA – Arbejde med epoxy og isocyanater på anlæg m.v. (epoxy-
uddannelse)).
Work with scaffold erection (education in erection of scaffolds) (DA – Ar-
bejde med opstilling af stilladser (uddannelse i opstilling af stilladser)).
Work with styrene on offshore installations (education in working with sty-
rene) (DA – Arbejde med styren (uddannelse i arbejde med styren)).
Danish Agency for Higher
Education
Cluster 1 – MANUFACTURING
Certified Pyrotechnician (DA – festfyrværker)
Competent authority: Danish Safety Technology Authority
Cluster category: Manufacturing
Type of action: 1+2 (expected)
Current situation
The profession is regulated by reserves of activities. The educational requirements
are short courses of 2-3 days of duration. The objective with this regulation is pub-
lic health, and the measure taken aims to maintain an acceptable level of safety
when using fireworks. The measure shall prevent accidents caused by fireworks,
fire and explosions with injury to persons, property and the environment. Fur-
thermore, the measure ensures that fireworks which presents high hazard are only
used by pyrotechnists with special training or persons who otherwise have docu-
mented the necessary knowledge of these types of fireworks.
New situation/ actions
In 2013, the profession was examined by a governmental task force (established as
a part of the Governments’ competitiveness policy package from 2012). It was con-
cluded that approvals and licenses within the area of fireworks could be combined
in a common application system. It is expected that the new system will be
launched spring 2016.
Furthermore, as regards to the education as certified pyrotecnician an analysis of
how to lower the educational requirements has been launched. It is expected that
the modernisation of the education will take place summer/autumm 2016.
Time frame
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It is expected that the new application system will be launched and that the mod-
ernisation of the education will take place summer/autumn 2016.
Cluster 1 – REAL ESTATE
Real Estate Agent (DA- ejendomsmægler)
Competent authority: The Danish Business Authority (DA – Erhvervsstyrelsen)
Cluster category: Real estate
Type of action: 1 (decided)
Current situation
The profession is regulated by reserves of activities. Both educational and profes-
sional requirements exist. Thus, in order to become a real estate agent, the appli-
cant must have an Academy Profession (AP) Degree in Financial Advice or three
courses from the Academy Profession Degree in Financial Advice. These three
courses are: Sale of Real Estate 1 (ejendomhandel 1), Sale of Real Estate 2 (ejen-
domshandel 2) and Turnover of Real Estate (omsætning af fast ejendom). The pro-
fessional requirement is that an applicant must have two years of relevant work
experience within real estate
59
.
The objective of the regulation is consumer protection.
New situation/actions
In 2013, the Danish Business Authority concluded a report, “Analysis on parts of
The Act on sale of real estate” (DA – “Analyse af dele af lov om omsætning af fast
ejendom”) to see if the Act should be amended. In this rapport it was discussed
whether the regulated requirements for real estate agents should be abolished. The
report concluded that if the requirements were to be abolished, it would lead to less
consumer protection and increase the risk of consumers getting poor counseling.
However, other improvements in this regard have taken place. In January 2015, a
new law entered into force. With this new law, buyer-counselling is no longer a
reserved activity. Now, everyone can do business as a buyer-counsellor whereas the
old law required that a buyer-counsellor was a recognised real estate agent. It is
expected that this deregulation will lead to further activity in the market for real
estate and, as a result, will create economic growth.
Time frame
Besides the above mentioned new law that entered into force in January 2015,
which reduces the scope of reserved activities, no further action is planned at the
moment. However, there is an ongoing review of the requirements to make sure
that they serve their intended purposes and that the scope of reserved activities is
reduced if necessary.
59
Danish Agency for Higher
Education
Article 6 in the Act of Sale of Real Estate
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National Action Plan for regulated professions - DENMARK
Cluster 1 – TRANSPORT
Harbour Pilot (DA – Lods)
Competent authority: the Danish Maritime Authority
Cluster category: Transport
Type of action: 2 (decided)
Current situation
The profession is regulated by reserves of activities. Only persons with a valid pilot
certificate issued by the Danish Maritime Authority are allowed to perform the
reserved activities. The requirements stated in the Ministerial Order on the Issuing
of Pilot Certificates and Pilot Exemption Certificates
60
must be met in order to be
granted a certificate. When granting certification, information such as the following
is taken into account: certificates, diplomas etc. relevant to the education; infor-
mation on the total duration of the studies and the subjects studied, specifying the
time allocated to each subject (e.g. hours, weeks or ECTS points), and where ap-
propriate the balance between the theoretical part and the practical part; infor-
mation on continuous professional development, seminars and all forms of training
attended in addition to the initial training (if any); proof of professional experience,
e.g. pay slips or attestations from employers identifying the professional activity
and its duration (if any) and Seafarer’s certificate (the original document).
The objectives with the regulation are safety at sea in Danish territorail water, pro-
tection of the environment, prevention of oil spill in connection with groundings
etc.
New situation/ actions
The regulation is regulated by International Maritime Conventions and EU-law. A
revision of the requirements for the education and training of harbour pilots and
maintenance of certificates has been considered and resulted in the report “Analyse
af det danske lodsmarked”, December 2013 (Analysis of the Danish pilot market,
December 2013). This formed the basis for an amendment of the Danish Pilotage
Act which was passed in 2014. The amendment has resulted in simplified docu-
mentation requirements from pilot and pilotage to the Danish Maritime Authority,
and the documentation requirements can to a larger extent be handled electronical-
ly. However, this does not change the educational requirements to the harbour
pilots or the certificates they are required to hold. It was considered to change the
educational requirements but during the political debates about the amendment of
the Act, a concern was expressed in relation to safety. The national legal require-
ments are considered to be sufficient, and therefore, no actions are planned.
A complete review of the Pilotage Act is planned to take place in 2018/2019 on the
basis of, among other things, the experience with the Act from 2014.
Danish Agency for Higher
Education
60
Ministerial Order no. 1077 of 21 November 2012
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Time frame
As mentioned above, a complete review of the Pilotage Act is planned to take place
in 2018/2019 on the basis of, among other things, the experience with the Act from
2014.
Ship’s assistant, Seaman and Motorman (DA – Skibsassistent/ matros
og motormand), Ship’s Cook (DA – skibskok), Ship's Deck officer class
II / 1st mate (DA – Overstyrmand),
Competent authority: the Danish Maritime Authority
Cluster category: Transport
Type of action: 5
Current situation
In order to serve on board Danish ships in any of the above-mentioned positions, a
certificate of competency within the relevant service is required.
In order to be granted a certificate of competency, which is issued by the Danish
Maritime Authority, the requirements set in the Ministerial Order on the Qualifica-
tion Requirements of Seafarers and Fisherman and on Maritime Trading Certifi-
cates and Qualification Certifications
61
must be met. Danish law is regulated by the
STCW Convention as well as directive 2012/35/EU of 21 November 2012 amending
directive 2008/106/EC on the minimum level of training of seafarers. If the re-
quirements of the STCW Convention are met, the applicant can be issued with a
certificate of recognition. This can be achieved by means of training at a maritime
training institution approved in accordance with the provisions on approval of mar-
itime training institutions.
The objectives of the regulation are safety of life at sea, physical security for mem-
bers of trade, navigational safety, environmental protection and reduction of risk
for personal accidents.
New situation/ actions
The current legislation is considered to be sufficient, and therefore, no actions are
planned.
Danish Agency for Higher
Education
Marine Engineer (on fishing vessels) (DA – Maskinmester på (fiske-
skibe)), Chief Engineer (on fishing vessels) (DA – maskinchef (på fi-
skeskibe)), Master (DA – skibsfører), Deck officer class II fishing ves-
sel (DA – Skibsfører i fiskeskibe <45 meter (fiskeskipper af 3. grad)),
Deck officer class II fishing vessel (DA – Overstyrmand i fiskeskibe
<45 meter (styrmand af 3. grad i fiskeskibe)), Fisherman and Master
of a Fishing Vessel (DA – Fisker og fiskeskipper)), Skipper/deck officer
fishing fleet (DA – Overstyrmand i fiskeskibe > 45 meter (styrmand af
1. grad i fiskeskibe)), Skipper/deck officer fishing fleet (DA – Skibsfø-
rer i fiskeskibe > 45 meter (fiskeskipper af 1. grad))
61
Ministerial Order no. 1145 of 29 September 2015
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Competent authority: the Danish Maritime Authority
Cluster category: Transport
Type of action: 5
Current situation
In order to serve on board Danish ships in any of the above-mentioned positions, a
certificate of competency within the relevant service is required.
In order to be granted a certificate of competency, which is issued by the Danish
Maritime Authority, the requirements set in the Ministerial Order on the Qualifica-
tion Requirements of Seafarers and Fisherman and on Maritime Trading Certifi-
cates and Qualification Certifications
62
must be met. This can be achieved by means
of training at a maritime training institution approved in accordance with the pro-
visions on approval of maritime training institutions.
The objectives of the regulation are safety of life at sea, physical security for mem-
bers of trade, navigational safety, environmental protection and reduction of risk
for personal accidents.
Danish Agency for Higher
Education
New situation/ actions
The current legislation is considered to be sufficient, and therefore, no actions are
planned.
Cluster 1 - WHOLE SALE AND RETAIL
Fertiliser sample expert (Professional user of pesticides) (DA –
sprøjtecertifikat)
Competent authority: The Danish Environmental Protection Agency
Cluster category: Wholesale and retail
Type of Action: 2 (expected)
Current situation
The profession
63
is regulated by reserves of activities. Professional use of plant pro-
tection products shall only be handled by persons who have acquired the certifi-
cate
64
. The objectives are public health as well as protection of the environment and
animals. The license is obtained after completion oc courses lasting from about 5
hours (to control moles and voles) to 4 days (to control vermin in stores for cereal,
seed and so on).
New situation
In February 2013 the Danish Pesticides strategy 2013-2015 was published. The new
pesticides strategy ensures Danish compliance with its commitments in relation to
Ministerial Order no. 1145 of 29 September 2015
The Chemical Substances and Products Act 849/2014, article 38 b.
64
The Statutory Order 825/2013 about professional use of plant protection products
62
63
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the EU framework directive on sustainable use of pesticides (2009/128/EC) and
also focuses on the work in connection with the new pesticides regulation which
entered into force in June 2011(1107/2009/EC). The new regulation in Denmark
concerning training for professional users of pesticides is expected early 2016. Mi-
nor changes to improvement of the system are considered at Danish level. For ex-
ample, the education will undergo changes for the purpose of modernising the reg-
ulation and further digitalisation will be introduced in relation to a new authorisa-
tion process administered by the Danish Environmental Protection Agency.
Time frame
Changes are expected early 2016.
Pet shops (DA - Dyrehandler)
Competent authority: The Danish Veterinary and Food Administration
Cluster category: Wholesale and retail
Type of action: 5
Current situation
The profession is regulated by reserves of activities. According to the Animal Wel-
fare Act
65
section 18, a pet store must have permission from the authorities. The
conditions of a pet store must be checked and approved as acceptable before it
opens.
In order to get access to the profession, the person in question must have a 2 year
vocational education at the secondary education level or single courses that up-
grade the owner and staff to the same level.
The objectives with the regulation are animal health and welfare.
New situation/actions
No actions are planned within this profession since the system is working as in-
tended.
Danish Agency for Higher
Education
Bandagist (DA - Bandagist), optometrist (DA – kontaktlinseoptiker/
optometrist) and audiometry (DA – Audiometri og høreapparat-
tilpasning)
(These professions are accounted for together).
Competent authority: Danish Patient Safety Authority.
Cluster category: Health.
Type of action: 5
Current situation
These professions are regulated by reserves of activities. Educational requirements
consist of post-secondary formal education leading to the profession in question.
65
Ministerial order on the Animal Welfare Act no. 1150 of 12 September 2015
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The duration of the education/training programmes is 3.5 years for optometrists,
2.5 years for audiometry and 5.5 years for bandagists. The objective with the regu-
lations is public health. In order to secure the protection of patients, it is necessary
to make sure that only people who have the necessary qualifications and training
can receive an authorisation. To perform the reserved activities, a certain level of
professional knowledge is required. This specific professional knowledge is
achieved by relevant education and training.
New situation/ actions
It has not been considered to use alternative mechanisms to achieve the objective
as the current system is working as intended. Changing the system is thus not con-
sidered to be beneficial.
Danish Agency for Higher
Education
Cluster 2 – PUBLIC SERVICES AND EDUCATION
Firefighter (DA – Brandmand)
Competent authority: Danish Emergency Management Agency
Cluster category: Public Services and Education
Type of action: 5
Current situation
The training is regulated by national law
66
. In order to become a firefighter, the
following courses must be completed: First Aid Training (12 hours); Basic Training,
Incident response (74 hours) and Advanced Training, Incident response (148
hours).
The legally regulated training qualifies the person to carry out the operational tasks
as a firefighter in connection with incidents covered by the Emergency Manage-
ment Act, encompassing manual tasks in connection with the response by the res-
cue services to fire-, rescue and chemical incidents. Other tasks that a firefighter
may carry out are not reserved activities and thus not legally regulated and hence
not covered by the training requirement. The objective with the regulation is the
protection of public security, public health, the environment and the urban envi-
ronment, including town and country planning.
New situation/ actions
No action has been taken recently and no action is planned as the reasons for regu-
lating the training remains valid.
The Emergency Management Act (Consolidation Act no. 660 of June 10, 2009, as amended by act no.
514 of May 26, 2014) and the Ministerial Order on Personnel in the Fire and Rescue Services (Order no.
41 of January 21, 1998, as amended by Order no. 49 of January 27, 2006, Order no. 192 of March 18,
2008, Order no. 1395 of December 10, 2010, Order no. 331 of March 30, 2012, Order no. 154 of Febru-
ary 12, 2013, Order no. 1481 of December 19, 2014 and Order no. 1843 of December 18, 2015)
66
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Team leader in the Emergency Service/Fire brigade (DA - Holdleder i
redningsberedskabet/brandvæsnet)
Competent authority: Danish Emergency Management Agency
Cluster category: Public Services and Education
Type of action: 5
Current situation
The training is regulated by national law
67
. In order to become a team leader in the
emergency service/fire brigade, completion of the following courses is a prerequi-
site: First Aid Training (12 hours); Basic Training, Incident response (74 hours)
and Advanced Training, Incident response (148 hours). Furthermore, the following
courses must be completed: Basic team leader training (37 hours) and Advanced
team leader training (148 hours).
The legally regulated training qualifies the person to carry out the professional
operational tasks as a team leader in the emergency service/fire brigade in connec-
tion with incidents covered by the Emergency Management Act, encompassing
management of the team during an incident response, the responsibility for the
safety of the fire fighters (the team) during the turn out, and under certain circum-
stances being in charge of the technical response and participating in the inter-
agency cooperation and coordination that takes place within the incident area.
Other tasks that a team leader in the emergency service/fire brigade may carry out
are not reserved activities and thus not legally regulated and hence not covered by
the training requirement. The objective with the regulation is the protection of
public security, public health, the environment and the urban environment, includ-
ing town and country planning.
New situation/ actions
No action has been taken recently and no action is planned as the reasons for regu-
lating the training remains valid.
Danish Agency for Higher
Education
Incident Commander in the municipal fire brigade (DA - Indsatsleder i
redningsberedskabet)
Competent authority: Danish Emergency Management Agency
Cluster category: Public Services and Education
Type of action: 5
Current situation
The training is regulated by national law
68
. In order to become an incident com-
mander in the municipal fire brigade, completion of the following courses is a pre-
requisite: First Aid Training (12 hours); Basic Training - Incident response (74
hours); Advanced Training - Incident response (148 hours); Basic team leader
67
68
Ibid
Ibid
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training (37 hours) and Advanced team leader training (148 hours). Furthermore,
the following courses must be completed: Basic incident commander training (148
hours) and Interdisciplinary incident commander training (111 hours).
The legally regulated training qualifies the person to carry out the operational tasks
as an incident commander in the municipal fire brigade in connection with inci-
dents covered by the Emergency Management Act, encompassing the responsibility
for the technical response of the municipal fire brigade to fire, rescue and chemical
incidents, the coordination and cooperation with other authorities during an inci-
dent response, responsibility for the safety of the personnel within the incident area
and responsibility for cooperation and coordination with other authorities on site.
Other tasks that the incident commander in the municipal fire brigade may carry
out are not reserved activities and thus not legally regulated and hence not covered
by the training requirement. The objective with the regulation is the protection of
public policy, public security, the environment and the urban environment, includ-
ing town and country planning.
New situation/ actions
No action has been taken recently and no action is planned as the reasons for regu-
lating the training remains valid.
Danish Agency for Higher
Education
Fire safety inspector (DA – Brandteknisk sagsbehandler)
Competent authority: Danish Emergency Management Agency
Cluster category: Public Services and Education
Type of action: 5
Current situation
The training is regulated by national law
69
. In order to become a fire safety inspec-
tor, completion of the following courses is a prerequisite: Basic team leader train-
ing (37 hours) and Advanced team leader training (148 hours). Furthermore, the
following courses must be completed: Basic technical fire safety training (144
hours) and Advanced technical fire safety training (144 hours).
The legally regulated training qualifies the person to carry out the administrative
and technical tasks as a municipal fire safety inspector in buildings etc. covered by
the Emergency Management Act. Other tasks that the fire safety inspector may
carry out are not reserved activities and thus not legally regulated and hence not
covered by the training requirement. The objective with the regulation is the pro-
tection of public policy, public security, the environment and the urban environ-
ment, including town and country planning.
New situation/ actions
No action has been taken recently and no action is planned as the reasons for regu-
lating the training remains valid.
69
Ibid
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National Action Plan for regulated professions - DENMARK
Primary school teacher (DA – folkeskolelærer)
Competent authority: the Danish Ministry of Higher Education and Science/the
Danish Agency for Higher Education
Cluster category: Public Service and education
Type of action: 1 (decided)
Current situation
The profession is regulated by education. The diploma is obtained by a full-time
degree programme (240 ECTS) at bachelor/graduate level at a University College
in Denmark. The BA of Education is a 240 ECTS concurrent teacher education
programme that combines four main elements: (1) The teacher’s foundational
competences (general didactics, pedagogy, special needs education, Danish as sec-
ond language and general education), (2) Teaching subjects, (3) Teaching practice
(30 ECTS points) and (4) The Bachelor of Education project
70
.
The license is obtained upon the successful completion of the BA of Education pro-
gramme. This involves completing modules equal to 240 ECTS, passing all exams
in the obligatory elements and passing the exams of at least two teaching subjects.
There is no separate certification process.
The education gives right to educate pupils in an age range from 5/6-16/17 in a
variety of subjects such as Danish, English, Mathematics, creative subjects and
many more. All permanently employed teachers have to be qualified to teach at
least two different subjects. Teachers prepare pupils for further education in an
upper secondary level and prepare pupils for citizenship by understanding their
rights and duties in an open democratic society. Teachers educate children about
Danish history and culture as well about respect and understanding for other cul-
tures and societies in a globalised world. Guidance counsellors and swimming in-
structors must complete further education to perform their duties as guidance
counsellors and swimming instructors.
The requirements regarding formal educational background and pedagogical and
didactic training for teachers in the primary and lower secondary school are based
on the fact that teaching in these schools is carried out at a highly professional level
which requires well-trained teachers. The main purpose of primary and lower sec-
ondary education is to ensure that pupils have the right basis for further education.
The requirements make sure that primary school teachers have the necessary quali-
fications to teach primarily through games and other developing activities.
New situation/actions
With the reform of the municipal primary and lower secondary schools (DA: folke-
skolereformen)
71
in 2014, it is possible for staff with different training and qualifi-
cations to be included in the organisation of teaching pupils and specific training
requirements relating to for example the function as school librarian has been re-
pealed. Pedagogues can to a limited extend within their qualifications carry out
teaching assignments in the first years of primary school.
Ministerial order no. 1068 of 8 September 2015
Consolidated Act no. 665 of 20 June 2014
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Danish Agency for Higher
Education
70
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The teacher education programme was reformed in 2012/13. The main components
of the reform were (a) the introduction of entrance exams (for applicants with be-
low average GPA), (b) a shift from content-based curriculum to output-based com-
petence-oriented curriculum and (c) a shift from a static subject-based organisation
of the programme to a flexible, module-based structure.
Alternative pathway to a teaching license
The so-called “merit-teacher” programme is an alternative pathway to become a
certified teacher in primary and lower secondary schools. The merit-teacher pro-
gramme is a two and a half year programme, corresponding to 150 ECTS points.
The programme consists of the following three main elements: Pedagogy and the
teaching profession; 2-4 main subjects and teaching practice
Danish Agency for Higher
Education
Upper secondary school teacher (DA – lærer i de gymnasiale uddan-
nelser)
Competent authority: The Danish Ministry of Higher Education and Science/the
Danish Agency for Higher Education
Cluster category: Public service and education
Type of action: 5
Current situation
The profession is regulated by education. To gain access to the profession the can-
didate must hold a university degree in an academic discipline that corresponds
with the teaching subject(s) and with an academic level at least similar to the Dan-
ish Academic Minimum Requirements (DA - “de faglige mindstekrav”) related to
the specific teaching subjects (e.g. minimum requirements regarding Chemistry or
History)
72
. In addition to this, the candidate has to complete the one year “pæda-
gogikum”. In other words, teaching in Danish upper secondary schools can only be
performed by teachers who have completed the Danish professional postgraduate
teacher training for upper secondary school teachers (DA - “pædagogikum”). The
Danish upper secondary education system includes The Gymnasium (DA - stx), The
Higher Commercial Examination Programme (DA - hhx), The Higher Technical
Examination Programme (DA - htx), The Higher Preparatory Examination (DA -
hf), and upper secondary level subjects in connection with vocational education
and training (DA - eux).
The “pædagogikum” is a one year education aimed at providing newly hired candi-
dates (DA -“pædagogikumkandidater”) in upper secondary schools with the didac-
tical teaching skills, the educational theory, and the regulatory and organisational
knowledge necessary for functioning as a teacher in these institutions. The aim is
also to teach the candidate how to actively engage in decision-making processes in
relation to their subject-related teaching activities in the organisation and in inter-
action with the surrounding society. The education consists of both a theoretical
and a practical part. The theoretical part and the practical part must be organised
Executive Order on Professional Postgraduate Teacher Training for Upper Secondary School Teachers
(”Pædagogikumbekendtgørelsen”), § 4
72
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in complementation of each other
73
. The “pædagogikum” diploma gives the candi-
date the right to function as a teacher in an upper secondary education institution
in Denmark and the right to function as internal and external examiner during the
examination of the pupils in all upper secondary education institutions in Den-
mark.
The diploma is obtained after completion of the theoretical and the practical part of
education
74
. The Danish Agency for Higher Education can decide that a high school
teacher from another country can gain access to the profession without a “pæda-
gogikum” diploma if the candidate is an EU/EEA citizen or a family member of an
EU/EEA citizen
75
, and already is qualified as a secondary school teacher in another
EU/EEA country
76
. If the candidate’s qualifications differ much from the Danish
academic minimum requirements, the candidate can either complete a selection of
tests arranged by the Agency for Higher Education or gain access to the profession
for a limited period of time (typically one year).
77
The requirements regarding for-
mal educational background and pedagogical and didactic training for upper sec-
ondary school teachers are based on the fact that teaching in upper secondary
schools is carried out at a highly professional level, which requires well-trained
teachers.
The aim of the regulation of the profession is to maintain a high level of quality
assurance of this facilitated teaching and learning in the Danish upper secondary
schools
78
.
New situation/actions
No actions of deregulation are planned in the area of the regulated education. The
reason for maintaining the regulation of the Danish upper secondary profession by
law is to maintain a high quality in the teaching and learning held by teachers in
the Danish upper secondary education system. The formal requirements of access
to the profession regarding formal educational background and the “pædagogikum”
diploma ensure that the teaching in upper secondary schools is carried out at the
highest professional level.
The upper secondary education is a central part of the Danish school system as it
qualifies the students for admission to the higher education system and provides
students with basic academic knowledge and skills essential for all citizens in Den-
mark and in the European Union.
Danish Agency for Higher
Education
Teacher, Danish Language Training Programmes for Adult Foreig-
ners (DA – Lærer i dansk for voksne udlændinge)
Executive Order on Professional Postgraduate Teacher Training for Upper Secondary School Teachers
(”Pædagogikumbekendtgørelsen”), § 3
74
Executive Order on Professional Postgraduate Teacher Training for Upper Secondary School Teachers
(”Pædagogikumbekendtgørelsen”), § 31
75
Directive 2004/38/EC of the European Parliament and of the Council of 29 April 2004
76
Executive Order on Professional Postgraduate Teacher Training for Upper Secondary School Teachers
(”Pædagogikumbekendtgørelsen”), § 29
77
Executive Order on Professional Postgraduate Teacher Training for Upper Secondary School Teachers
(”Pædagogikumbekendtgørelsen”), § 29
78
Executive Order on Professional Postgraduate Teacher Training for Upper Secondary School Teachers
(”Pædagogikumbekendtgørelsen”), § 2
73
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National Action Plan for regulated professions - DENMARK
The competent authority: The Ministry of Immigration, Integration and Housing.
Cluster category: Public services and education.
Type of action: 5
Current situation
The profession of teacher in Danish Language Training Programmes for Adult
Foreigners is regulated by reserves of activities
79
(Teaching in “Danish Education
1-3” and labour market-oriented Danish). Getting access to the profession as a
teacher in Danish language targeted adult foreigners requires that the person has
undertaken and completed a specific additional study/education on teaching the
Danish language for foreigners.
Access to the education as teacher of Danish for adult foreigners normally requires
an education as teacher with the main subject training in languages, a B.A. that
includes language as a core subject, or another programme where similar condi-
tions have been acquired. The education programme as teacher of Danish for adult
foreigners normally takes 1 year.
If a person does not have the required qualifications he or she can be permitted to
work as a teacher on the condition that the person is enrolled for and actively un-
dertaking the study. Furthermore, the study has to be completed within a period of
three years.
The objective with the reg ulation is to ensure that persons teaching adult foreign-
ers in the Danish Language have the required qualifications for the benefit of inte-
gration of immigrants and refugees in Denmark.
Mastering Danish is a prerequisite for successful integration in Denmark. Likewise
is the knowledge of culture and society in Denmark.
New situation/actions
No actions are planned as the regulation is considered to be suitable in order to
secure the needed and adequate qualifications.
Danish Agency for Higher
Education
Pedagogues in 1st–3rd grade (DA – pædagog i børnehaveklasse – 3.
klassetrin (skolepædagog))
Competent authority: The Danish Ministry of Higher Education and Science/the
Danish Agency for Higher Education
Cluster category: Public services and education
Type of action: 4 (decided)
Current situation
The profession is regulated by education. The diploma is obtained by a full-time
degree programme (210 ECTS) at bachelor/graduate level at a University College in
Denmark (Bachelor’s degree programme in Social Education/Bachelor in Social
Education). The purpose of the education is for the student to acquire relevant
professional competences, knowledge and skills and to be able to manage, develop
Consolidation Act on Danish Language Courses for Adult Foreigners no. 772 of 10 June 2015 and
Ministerial Order on Danish Language Courses for Adult Foreigners etc. no. 65 of 22 February 2014
79
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and convey development, learning and care assignments in a social perspective,
both independently and in collaboration with others. With a starting point in the
conditions and perspectives of children, adolescents and adults, the student is able
to establish, assess and evaluate pedagogical environments and activities that sup-
port the development of children, adolescents and adults, and to account for pro-
fessional evaluation and choices.
Pedagogues and pre-school teachers (with an education as pedagogue) can perform
teaching in kindergarten classes. In 1st - 3rd grade pedagogues can undertake de-
fined teaching assignments in the subjects within their skills and qualifications in
general. In addition, pedagogues can perform supportive teaching at all grade lev-
els.
New situation/actions
In September 2013, a political agreement was reached on a reform of the Bachelor’s
Degree Programme in Social Education aimed at supporting the goal of social mo-
bility and breaking the intergenerational transmission of disadvantage through
early action, with the aim of ensuring that more young people develop the ability
needed to complete an education. The reform was implemented in the legislation in
January 2014. The main components of the reform were: improved skills and quali-
ty, action competencies and coherence to practice, increased specialisation with
more relevance for the labour market and a strengthening of the inter-professional
competences.
Furthermore, with the reform of the municipal primary and lower secondary
schools (DA: folkeskolereformen)
80
in 2014, it is possible for staff with different
training and qualifications to be included in the organisation of teaching pupils and
specific training requirements. Pedagogues can to a limited extend within their
qualifications carry out teaching assignments in the first years of primary school.
The profession has become regulated because it is considered necessary to use the
pedagogical professionalism in teaching pupils in primary school. In connection
with the latest reform of the municipal primary and lower secondary schools and
the introduction of the longer school day, the need to create new and better oppor-
tunities to involve teachers and staff to support and complement teachers with
other relevant qualifications in the school was stated (sections 29 a and 30 in the
Consolidation Act on primary and lower secondary schools
81
). The competences of
pedagogues will, for example, be particularly relevant in connection with activities
related to the overall development of pupils where pedagogues can pay particular
attention to the social well-being of the students, their concentration, understand-
ing of assignments etc. To ensure the quality of the supportive teaching carried out
by pedagogues, it must carried out in collaboration with teachers, pedagogues and
staff with other relevant skills.
Time frame
The regulation was introduced in 2014.
Danish Agency for Higher
Education
80
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Consolidated Act no. 1534 of 11 December 2015
Consolidation Act no. 1534 of 11 December 2015
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National Action Plan for regulated professions - DENMARK
Driving instructor (DA - Kørelærer)
Competent authority: Ministry of Transport and Building
Cluster category: Public services and education
Type of action: 4 (decided)
Current situation
The driving instructor profession is regulated by reserves of activities. According to
Ministerial Order on Approval of Driving Instructors
82
, it is required that driving
instructors obtain a driving instructor’s license from the Danish National Police
before engaging in the reserved activities.
A driving instructor is responsible for teaching driving students about the driving
theory, i.e. road traffic regulations and risk factors related to various road condi-
tions and risks involved in the movement and driving of various types of vehicles. A
driving instructor is also responsible for instructing driving students in the driving
training facility and slippery road facility and practical driving on the road. A driv-
ing instructor is the key person in transmitting road safety to driving students. It is
the responsibility of the driving instructor to influence the later behavior of the
driving students to a safe and responsible way of driving.
New situation/ actions
In 2013, the Danish Ministry of Justice appointed a committee to discuss and pro-
pose amendments to the rules governing the driving instructor education. The de-
liberations of the committee resulted in a report providing recommendations to
new requirements for approval and supplementary training of driving instructors.
Subsequently, the Danish Ministry of Justice submitted an amending act of the
Road Traffic Act implementing the recommendations of the committee. The
amending act
83
was passed and came into force on 1 April 2014. The objective of
the regulation is road safety, and the amending act of the Danish Road Traffic Act
introduces a number of new requirements that must be met as a precondition for
obtaining a driving instructor license. The purpose of these conditions is to im-
prove the quality of the education of driving instructors and to make sure that the
driving instructors continue their professional development through training. The
conditions relate to age, eligibility, driving experience and completed pedagogical
training. This has also been reflected in the sector report from Denmark for the
mutual evaluation of driving instructors.
Furthermore, the Ministerial Order on approval of Driving Instructors
84
has im-
plemented the Directive 2005/36/EF of 7 September 2015 on the recognition of
professional qualifications.
Time frame
Since the amending act of the Road Traffic Act in 2014, no new actions are fore-
seen.
Danish Agency for Higher
Education
Ministerial Order no. 99 of 29 January 2015
Amending Act no. 245 of 19 March 2014
84
Ministerial Order no. 99 of 29 January 2015
82
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National Action Plan for regulated professions - DENMARK
Cluster 2 - OTHER
Zoological Taxidermist (DA – Zoologisk konservator)
Competent authority: The Danish Nature Agency
Cluster category: Other
Type of action: 5
Current situation
The profession is regulated by reserves of activities. To obtain authorisation as a
zoological taxidermist, a formal education and examination is required. In order for
a person to be authorised, he/ she must therefore have acquired a diploma from
either the Danish Association of Zoological Taxidermists/an authorised zoological
taxidermist company (four years of craft’s apprenticeship) or from School of Con-
servation, The Royal Danish Academy of Fine Arts (a three year’s bachelor pro-
gramme). The profession is regulated in the Ministerial Order on commercial taxi-
dermy of certain species
85
.
The objectives with the regulation are protection and conservation of protected and
endangered species. In order to secure the protection of these species, it is neces-
sary to ensure that only persons with the necessary qualifications and training are
authorised. Experience demonstrates that companies not having a Zoological Taxi-
dermist with proper knowledge about legislation and species employed have diffi-
culties with fulfilling the obligations regarding legal marking and registration.
To fulfill Directive 2009/147/EC of the European Parliament and of the Council of
30 November 2009 on the conservation of wild birds, the Danish legislation re-
garding the authorisation as Zoological Taxidermist has a strict system of registra-
tion and marking of the species received by the Zoological Taxidermist.
New situation/actions
Implementation of directive 2005/36/EC is planned to enter into force in the na-
tional legislation in January 2016 making it possible for persons who have qualifi-
cations from other EU member states to practice in Denmark according to art. 49
EUF and Art 56 EUF.
Danish Agency for Higher
Education
Rearing of certain types of animals (persons responsible for rearing
deer/ratites/foxes and feathered game) (DA – opdræt af visse dyreart-
er: hjortedyr, strudsefugle, ræve og fjervildt)
Competent authority: The Danish Veterinary and Food Administration
Cluster category: Cluster 2, other
Type of action: 5
Current situation
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The profession is regulated by reserves of activities which consist of running the
operation of a rearing with one of the above mentioned animal species.
Practice of this profession requires a specific professional knowledge, and it is
therefore required that the breeder should have completed a course in keeping the
specific species.
The keeping of one of the above mentioned species for agricultural purposes shall
initially be registered by the owner at The Danish Veterinary and Food Administra-
tion. As a keeper, you can run the operation of a holding with these animals. Ac-
cording to the Act on ban on the keeping of foxes
86
, keeping foxes is no longer al-
lowed, and it has not been allowed to establish fox farms since 1 August 2009, at
which time the Act came into force.
Persons in charge of a keeping with one of the species must have completed a
course approved by The Danish Veterinary and Food Administration on farming of
the species in question. The course must be completed within 1 year after the per-
son has assumed responsibility for the breeding. However, for farms with ratites,
the course must be completed prior to taking over responsibility for the farm.
Courses: Deer: A total of 2 days (1 full day + 2 half days); Feathered/poultry: 3
days; Ratites: The courses have a duration of 3 days, but due to lack of interest in
ratite farming in Denmark, it is several years since the last approved course was
held, and there has not been basis for reviving the courses.
The objectives with the regulation are protection of animal welfare, protection of
the original genetics of the wild game population and prevention of contagious
diseases.
By requiring that the keeper has gone through a specific course, it is ensured that
the keeper has sufficient knowledge of rearing these species for agricultural pur-
poses so that it can be carried out with due respect for the animals’ natural behav-
ior, ensuring the free game population and preventing contagious diseases. The aim
of the legislation includes implementing the basic provisions of the animal welfare
act in practical terms, specifically aimed at the species in question, which are not
traditionally kept for farming purposes and may have special needs.
New situation/actions
Apart from the ban on fox keeping as of 1 August 2009, there have not been any
amendments of the requirements for training of keepers of certain types of animals
(deer, feathered game and ratites). Neither are such amendments planned. The
current system is working as intended, and changing the system is not considered
to be beneficial.
Danish Agency for Higher
Education
Farmer of genetically modified crops (DA – dyrker af genetisk modi-
ficerede afgrøder)
Competent authority: The Danish AgriFish Agency
86
No. 466 of 12 June 2009
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National Action Plan for regulated professions - DENMARK
Cluster category: Cluster 2 - Other
Type of action: 5
Current situation
Farmers who wish to cultivate or handle genetically modified crops must have an
authorisation or a similar official recognition issued by the Danish AgriFish
87
. In
order to receive an authorisation, the farmer must have an education in the cultiva-
tion and handling of genetically modified crops in coexistence with conventional
and organic crops. The education must provide the farmer with competence re-
garding active observation of cultivation distances to neighbouring fields with a
crop of the same species as the genetically modified species or a genus that can be
crossed with it and cultivation intervals between cultivation of a genetically modi-
fied crop and subsequent cultivation of a conventional or organic crop of the same
species. Furthermore, the education should make the farmer aware of the obliga-
tion to inform neighbours of the intended cultivation of genetically modified crops
and of the need to report to the Danish AgriFish Agency on location of fields with
genetically modified crops etc. Eventually the education should draw farmers’ at-
tention to the necessary cleaning of machinery used for sowing, harvest and
transport of genetically modified crops.
The requirements make sure that a farmer possesses the necessary qualifications to
handle and avoid the risks of genetically modified crops, as the farmer is responsi-
ble for the presence of genetically modified material above a certain limit in con-
ventional or organic crops, as a result of, e.g., pollen dispersal from his/her fields
with genetically modified crops. This would result in economic loss for the conven-
tional or organic farmers - and specifically for organic farmers the loss of the or-
ganic status of their fields in question. The farmer cultivating the genetically modi-
fied crops can be held responsible for the admixture, if he/she does not comply
with the specific rules which are set to minimise the dispersal of genetically modi-
fied material.
The measures (e.g., certain distances between fields with genetically modified crops
and conventional or organic crops) are designed to minimise the risk of economic
loss which conventional or organic farmers might experience in case of mixing with
genetically modified material.
So far, there have been no commercial cultivation of genetically modified crops in
Denmark and therefore, no information is available as to the operation of the rules.
New situation/actions
The activities in question intend to minimise the presence of genetically modified
material in neighbouring fields which are cultivated with conventional or organic
crops. Due to the specific rules of organic farming, which prohibit the presence of
genetically modified material in organic products, it is important that farmers who
cultivate genetically modified crops have been educated to handle this specific situ-
ation.
There are no current plans, therefore, to dismantle the present demand for an edu-
cation of farmers in the cultivation and handling of genetically modified crops.
Act no. 193 of 12 March 2009. Ministerial Order no. 176 of 28 February 2008 as amended by Ministe-
rial Order no. 1217 of 11 December 2009
87
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Education
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National Action Plan for regulated professions - DENMARK
Authorised Slurry Tank Inspector (DA - Autoriseret gyllebeholderkon-
trollant)
Competent authority: Environmental Protection Agency, The Ministry of Environ-
ment and Food of Denmark
Cluster category: Cluster 2 Other
Type of action: 5
Current situation
The profession is regulated by reserves of activities. The regulation requires that a
person seeking to work as a “gyllebeholderkontrollant” must require
88
an authori-
sation. In order to obtain this authorisation, the person must document certain
skills with regard to building technology in relation to slurry tanks. Furthermore,
the person must document professional experience within relevant areas such as
building assignments in relation to agriculture or similar sectors. The person seek-
ing to obtain the authorisation must also complete an introduction course; be regis-
tered as liable to pay VAT and must document to be covered by a professional in-
demnity insurance.
The regulated activities include, among others, establishing a team of authorised
and registered inspectors, completing 5 and 10 years’ inspection of slurry tanks at
the request from the owner of the tank in order to make sure that the slurry tank
meets with the requirements for strength and density under the ministerial order.
The authorised “gyllebeholderkontrollant” inspects slurry tanks in order to make
sure that these tanks with regard to strength and imperviousness are in line with
the standard required by the environmental protection regulation as leaks from
slurry tanks or actual collapses of slurry tanks causes a great risk of contamination
of the aquatic environment. The objective with the regulation is protection of the
environment.
New situation/actions
No actions have been taken. The regulation is still in place in order to secure the
protection of the environment.
Danish Agency for Higher
Education
Cluster 2 – FINANCIAL SERVICES
Financial advisor (DA - Finansiel rådgiver)
Competent authority: The Danish Financial Supervisory Authority (Danish FSA)
Cluster category Financial Services.
Type of action: 4 (decided)
Statutory Act no. 1322 of 14
th
of December 2012 regarding Inspection of Slurry Tanks for storage of
Livestock Manure and Silage Juice
The statutory act has its legal base in the Danish Environmental Protection Act (Act. No. 1317 of 19
th
of
November 2015)
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National Action Plan for regulated professions - DENMARK
Current situation
The profession is regulated by a Licensing system based on qualification for advice
on some types of financial instruments. The authorisation gives right to advice con-
sumers on all financial products. The advice can be given on credit agreements,
deposits, insurance, pensions and investment products.
As part of the application procedure, an investment advisor must present business
procedures for e.g. counselling, best practice, policy for handling of conflicts of
interests etc.Furthermore The DFSA makes a fit & proper assessment of the mem-
bers of the management.
Theoretical education (typical having a background in banking/financial services)
or minimum 2 years of practical experience by employment in a company where
the employee has given advice on financial products as mentioned above. License is
obtained by the Danish FSA. The objective with the regulations is protection of
consumers who receive financial advice.
New situation/actions
The law on financial advisors
89
is new. It was introduced in January 2014 with the
purpose of regulating financial advisors that are not employed in banks/the finan-
cial sector. The regulation minimises the risk of consumers making decisions re-
garding financial products on a uniformed basis and taking unnecessary risks on
their personal finances.
Time frame
The regulation is still new since it entered into force in January 2014. It has not
been considered to change the system.
Danish Agency for Higher
Education
Investment advisor (DA – Investeringsrådgiver)
Competent authority: The Danish Financial Supervisory Authority (Danish FSA).
Cluster category: Financial Services.
Type of action: 5
Current situation
The profession is regulated by a licensing system based on qualification for advice
on some types of financial instruments. The authorisation gives right to advice on
some types of financial instruments such as stocks, shares, bonds, options, futures
and swaps.
As part of the application procedure, an applicant for investment advisor must
present business procedures for e.g. counselling, policy for handling of conflicts of
interests etc. Furthermore, the Danish FSA makes an assessment of the members
of the management.
An investment advisor must have sufficient qualifications on relevant legislation,
investment products and financial understanding. Whether an applicant for in-
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vestment advisor has the “sufficient qualifications” required by the Ministerial Or-
der
90
on competence requirements for persons who give advice about investment
products, is based on a specific assessment of the circumstances.
Furthermore, an investment advisor must be acquainted with the Ministerial Order
on Risk-Labelling of Investment Products
91
which divides investment products in
categories of “green”, “yellow” and “red". The investment advisor must be able to
explain the substance, risks and prices of investment products that are labelled
“green” or “yellow”. Regarding investment products labelled “red”, an investment
advisor must complete a test at an educational establishment in Denmark that en-
sures that the advisor has the necessary capabilities to advice on the product.
The objective with the regulation is protection of consumers and recipients of ser-
vices. The regulation minimises the risk of consumers making decisions of invest-
ments on an uninformed basis and decisions of investements that do not fit the
consumer’s risk profile.
New situation/actions
The present rules on investment advisors comply with the Professional Qualifica-
tion Directive (2013/55/EU). At the moment, there are no plans of changing the
regulation.
Danish Agency for Higher
Education
Responsible actuary (DA – ansvarshavende aktuar)
Competent authority: the Danish Financial Supervisory Authority
Cluster category: financial services
Type of action: 5
Current situation
The profession is regulated by reserves of activities. The requirements needed to
occupy a position as responsible actuary are the following
92
:
1) A university degree in actuarial mathematics from a Danish university
(MSc Actuarial Mathematics).
2) A similar degree, for example from another country.
Courses in the following subjects are mandatory: actuarial mathematics, life
insurance mathematics, Danish insurance law and insurance accounting. The
responsible actuary shall furthermore have performed fulltime practical actuarial
work for a life assurance company or the like for not less than six years within the
past ten years. Furthermore, one of the six years must have been in close
cooperation with a responsible actuary.
The responsible actuary shall as a minimum have obtained in-depth knowledge of
the preparation of notifications; bonus schemes; technical statements, including
90
Ministerial
91
Ministerial
Order no. 346 of 15 April 2011
Order no. 345 of 15 april 2011
92
Ministerial
Order no. 1089 on Responsible Actuary, Ministerial Order no. 1014 on Responsible Actuary
in Company Pension Funds. Furthermore, please see the Danish Financial Act art. 108.
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calculation of solvency requirements; calculation of provisions; and preparation of
the annual report to the Danish FSA
93
.
The objectives with these regulations are protection of consumers and recipients of
service. The requirements needed to occupy a position as responsible actuary are
rather extensive due to the fact that the responsible actuary has a double role. On
the one hand, the responsible actuary is working for the company by overseeing all
the actuarial aspects. On the other hand, the actuary needs to make reports to the
board of directors and an annual report to the Danish FSA. These reports need to
address any wrongdoings taking place in the company.
New situation/ actions
No new actions regarding responsible actuaries are planned. The reason for
keeping the regulation as it is is that the current regulation sets out reasonable
requirements for responsible actuaries.
Danish Agency for Higher
Education
Average Adjuster (DA - Dispachør)
Competent authority: The Danish Business Authority
Cluster category: Financial services
Type of action: 1 (decided)
Current situation
The profession is regulated by a protected title (without the reserves of activities).
An average adjuster provides statements (dispacher) about damages on ships or
cargo in relation to collisions or accidents in open sea. It is according to the Danish
Maritime Act that average adjusters shall provide the above mentioned statements.
The Danish Business Authority provides the certification of average adjusters. In
order to obtain a certification, applicants shall pass a special exam which is con-
ducted by the Average Adjuster Commission (DA: Dispachørkommissionen). Arti-
cle 1, section 2 of the Average Adjuster Act
94
lists the conditions for the certification
as average adjuster. The conditions are among others that you hold a master degree
in law and have 3 years of relevant working experience. As of today (December
2015), 3 people are certified as average adjusters in Denmark. The objectives with
the regulation are protection of consumers and recipients of services. The demand
of a law education and a special exam makes sure that average adjusters have the
necessary qualifications to ensure a high level of education, impartiality, independ-
ence and protection of the recipients of the services.
New situation/ actions
The former Danish Government launched in October 2012 its competition policy
programme, “Styrket konkurrence til gavn for Danmark ” (EN – “Strengthened
competition to the benefit of Denmark”). This work has resulted in an initiative
about abolishing the authorisation scheme to help promote strengthened competi-
tion.
In 2015, it has been decided that from 1 January 2016, the current system will be
93
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94
Order no. 1089 on Responsible Actuary article 3.
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removed without replacement. This means that after 1 January 2016, average
adjuster is no longer a protected title and it will no longer require a certification to
use the title of average adjuster or conduct the activities connected herewith. All
certifications will cease to exist and the public register of average adjusters on
VIRK.dk is deleted. The proposal is part of ”Aftale om en vækstpakke”, from June
2014, where The goverment , V, DF, SF and K agreed to a number of initiatives that
should ease market acces and remove uneccesary obstacles for a couple of smaller
professions.
Time frame
From 1 January 2016, the current system will be removed without replacement.
Insurance Intermediary (DA – Forsikringsformidler)
Competent authority: The Danish Financial Supervisory Authority (Danish FSA).
Cluster category: Financial Services.
Type of action: 2 (expected)
Current situation
The profession is regulated by reserved activities. The authorisation as insurance
intermediary gives the right to provide advice on the basis of an analysis of a large
number of available insurance solutions on the market and present the results for
the consumer. An insurance intermediary specialises in either in non-life insurance
or life insurance. As part of the application procedure The Danish FSA makes a fit
& proper assessment of the members of the management.
In order to obtain authorisation, the following education and training requirements
apply:
a. Theoretical education:
Theoretical education on part-time basis of 3-4 years’
duration. Duration of education depends on whether it is the “non-life insurance
Intermediary education” or the “life insurance Intermediary education”. Some in-
surance intermediaries complete both the non-life insurance and the life insurance
education and can thus provide advice within both areas. By January 2016, there is
only one educational establishment in Denmark (Forsikringsakademiet) that pro-
vides the insurance Intermediary education.
b. Practical experience:
In addition to the theoretical education, 2 years of practical
experience by full-time employment at an insurance company, insurance interme-
diary company or other occupation, where similar knowledge is acquired.
The objective with the regulation is to minimie the risk of consumers making deci-
sions regarding insurance on an uninformed basis.
New Situation/actions
In October 2012, the government launched its competition policy programme,
“Styrket konkurrence til gavn for Danmark” (EN – “Strengthened competition to
the benefit of Denmark”). In this connection, the regulation on Insurance Interme-
diary has been reviewed in order to establish whether the current regulation is still
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necessary, e.g. whether the general interest objective can be reached by less strict
measures.
In connection with the implementation of the new Insurance Distribution Directive
(IDD), which is to be implemented in the period 2016-2018, it is planned to mod-
ernise the insurance intermediary education.
The present rules on insurance intermediaries comply with the Professional Quali-
fication Directive (2013/55/EU).
Time frame
Within the next two years, it is planned to modernise the insurance intermediary
education.
Danish Agency for Higher
Education
Cluster 2 – HEALTH AND SOCIAL SERVICES
Physician (DA – læge), Dental Practitioner (DA – Tandlæge), Chiro-
practor (DA - Kiropraktor) and Pharmacist (DA - Farmaceut)
Competent authority: Danish Patient Safety Authority
Cluster category: Health
Type of action: 5
Current situation
These professions are regulated by reserves of activities. Educational requirements
consist of post-secondary formal education leading to the profession in question.
The duration of the education/training programmes mentioned is 5 to 6 years. The
objective with the regulations is public health. In order to secure the protection of
patients, it is necessary to make sure that only people who have the necessary
qualifications and training can receive an authorisation. To perform the reserved
activities, a certain level of professional knowledge is required. This specific profes-
sional knowledge is achieved by relevant education and training.
New situation/ actions
It has not been considered to use alternative mechanisms to achieve the objective
as the current system is working as intended. It is thus not considered to be benefi-
cial to change the system.
Dental hygienist (DA - Tandplejer), Dietitian (DA – Klinisk diætist),
Clinical Dental Technician (DA – Klinisk tandtekniker), Medical Labo-
ratory Technologist (DA – Bioanalytiker), Midwife (DA - Jordemo-
der), Nurse (DA – Sygeplejerske), Occupational Therapist (DA - Ergo-
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terapeut), Physiotherapist (DA - Fysioterapeut) and Radiographer
(DA - Radiograf)
Competent authority: Danish Patient Safety Authority.
Cluster category: Health.
Type of action: 5
Current situation
These professions are regulated by reserves of activities. Educational requirements
consist of post-secondary formal education leading to the profession in question.
Th duration of the mentioned education/training programmes is between 3 and 3.5
years. The objective with the regulations is public health. In order to secure the
protection of patients, it is necessary to make sure that only people who have the
necessary qualifications and training can receive an authorisation. To perform the
reserved activities, a certain level of professional knowledge is required. This spe-
cific professional knowledge is achieved by relevant education and training.
New situation/ actions
It has not been considered to use alternative mechanisms to achieve the objective
as the current system is working as intended. It is thus not considered to be benefi-
cial to change the system.
Danish Agency for Higher
Education
Pharmaconomist (DA - Farmakonom)
Competent authority: Danish Patient Safety Authority
Cluster category: Health
Type of action: 5
Current situation
The professions is regulated by reserves of activities. Educational requirements
consist of Vocational education at secondary education level leading to the profes-
sion in question. The duration of the mentioned education/training programmes is
3 years. The objective with the regulation is public health. In order to secure the
protection of patients, it is necessary to make sure that only people who have the
necessary qualifications and training can receive an authorisation. To perform the
reserved activities, a certain level of professional knowledge is required. This spe-
cific professional knowledge is achieved by relevant education and training.
New situation/ actions
It has not been considered to use alternative mechanisms to achieve the objective
as the current system is working as intended. It is thus not considered to be benefi-
cial to change the system.
Chiropodist (DA – Fodterapeut) and Social and Healthcare Assistant
(DA – Social- og sundhedsassistent)
Competent authority: Danish Patient Safety Authority.
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Cluster category: Health.
Type of action: 5
Current situation
These professions are regulated by reserves of activities. Educational requirements
consist of General Secondary Education leading to the profession in question. The
duration of the education/training programmes is 1.5 years for a Chiropodist and 3
years for a Social and Healthcare Assistant. The objective with the regulation is
public health. In order to secure the protection of patients, it is necessary to make
sure that only people who have the necessary qualifications and training can re-
ceive an authorisation. To perform the reserved activities, a certain level of profes-
sional knowledge is required. This specific professional knowledge is achieved by
relevant education and training.
New situation/ actions
It has not been considered to use alternative mechanisms to achieve the objective
as the current system is working as intended. It is thus not considered to be benefi-
cial to change the system.
Danish Agency for Higher
Education
Specialised Nurse in Infection Control (DA – Specialsygeplejerske i
infektionshygiejne), Specialised Nurse in Oncology (DA – Specialsy-
geplejerske i kræftsygepleje), , Specialised Nurse in Intensive Care
(DA – Specialsygeplejerske i intensive sygepleje), Specialised Nurse in
Psychiatry (DA – Specialsygeplejerske i psykiatrisk sygepleje), Public
Health Nurse (DA - Sundhedsplejerske).
Competent authority: Danish Patient Safety Authority.
Cluster category: Health.
Type of action: 5
Current situation
These professions are regulated by reserves of activities. Educational requirements
consist of post-secondary formal education leading to the profession in question.
The duration of education/training programmes is 1-1.5 years after training as a
nurse. The objective with the regulation is public health. In order to secure the pro-
tection of patients, it is necessary to make sure that only people who have the nec-
essary qualifications and training can receive a registration. To perform the re-
served activities, a certain level of professional knowledge is required. This specific
professional knowledge is achieved by relevant education and training.
New situation/ actions
It has not been considered to use alternative mechanisms to achieve the objective
as the current system is working as intended. Changing the system is thus not con-
sidered to be beneficial.
Specialist in Anaesthesiology (DA - Anæstesiologi), Occupational me-
dicine (DA - Arbejdsmedicin), Child and adolescent psychiatry (DA –
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Børne- og ungdomspsykiatri), Dermatology (DA – Dermato-
venerologi), Diagnostic Radiology (DA – Diagnostik radiologi), Gene-
ral medical practitioner, (DA – speciallæge i almen medicen), Gyna-
ecology and Obstetrics (DA – Gynækologi og obstretrik), Clinical Bio-
chemistry (DA – Klinisk biokemi), Clinical Pharmacology (DA – Kli-
nisk farmakologi), Clin. Physiology and Nuclear Medicine (DA – Kli-
nisk fysiologi og nuklearmedicin), Clinical Genetics (DA - Klinisk ge-
netik), Clinical Immunology (DA – Klinisk immunologi), Clinical Mi-
crobiology (DA – Klinisk mikrobiologi), Neurology (DA – Neurologi),
Neurosurgery (DA – Neurokirurgi), Ophthalmology (DA – Oftalmolo-
gi), Clinical Oncology (DA – Klinisk onkologi), Orthopaedical Surgery
(DA – Ortopædisk kirurgi), Oto-rhino-laryngology (DA – Oto-rhino-
laryngologi), Histopathology and Cytology (DA – Patologisk anatomi
og cytology), Psychiatry (DA - Psykiatri), Paediatrics (DA - Pædiatri),
Community Medicine/Public Health (DA - Samfundsmedicin), Internal
medicine:haematology (DA – Intern medicin: hæmatologi), Internal
medicine:infectious diseases (DA - Intern medicin: infektionsmedicin),
Internal medicine:cardiology (DA - Intern medicin: kardiologi), In-
ternal medicine:endocrinology (DA - Intern medicin: endokrinologi),
Internal medicine:gastroenterology and hepatology (DA - Intern me-
dicin: gastroenterology og hepatologi), Internal medicine:respiratory
diseases (DA - Intern medicin: lungesygdomme), Internal medici-
ne:nephrology (DA - Intern medicin: nefrologi), Internal medici-
ne:geriatrics (DA - Intern medicin: geriatric), Internal medici-
ne:rheumatology (DA - Intern medicin: reumatologi), Surgery (Da -
Kirurgi), Vascular Surgery (DA - Karkirurgi), Plastic Surgery (DA -
Plastikkirurgi), Forensic Medicine (DA - Retsmedicin), Thoracic Sur-
gery (DA - Thoraxkirurgi), Urology (DA - Urologi), and Specialised
dentist (DA - Specialtandlæge).
Competent authority: Danish Patient Safety Authority.
Cluster category: Health.
Type of action: 5
Current situation
These professions are regulated by reserves of activities. Educational requirements
consist of general post-secondary formal education leading to the profession in
question. The duration of the mentioned education/training programmes is be-
tween 5 and 6 years after training as a Physician or a Dentist. The objective with the
regulation is public health. In order to secure the protection of patients, it is neces-
sary to make sure that only people who have the necessary qualifications and train-
ing can receive a registration as a specialist. To perform the reserved activities, a
certain level of professional knowledge is required. This specific professional
knowledge is achieved by relevant education and training.
New situation/ actions
It has not been considered to use alternative mechanisms to achieve the objective
as the current system is working as intended. It is thus not considered to be benefi-
cial to change the system.
Danish Agency for Higher
Education
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Paramedic Assistant (DA – Ambulanceassistent), Paramedic (DA -
Ambulancebehandler) and Paramedic with special competences (DA –
Ambulancebehandler med særlig kompetence).
Competent authority: Danish Patient Safety Authority.
Cluster category: Health.
Type of action: 5
Current situation
These professions are regulated by reserves of activities. Educational requirements
consist of General Secondary Education leading to the profession in question. The
duration of the mentioned education/training programmes is between 2 and 3.5
years. The objective with the regulation is public health. In order to secure the pro-
tection of patients, it is necessary to make sure that only people who have the nec-
essary qualifications and training are allowed to work as a Paramedic. To perform
the reserved activities, a certain level of professional knowledge is required. This
specific professional knowledge is achieved by relevant education and training.
New situation/ actions
It has not been considered to use alternative mechanisms to achieve the objective
as the current system is working as intended. Changing the system is thus not con-
sidered to be beneficial.
Danish Agency for Higher
Education
Psychologist (DA Autoriseret psykolog)
Competent authority: The Danish Supervisory Board of Psychological Practice
Cluster category: Health and social services
Type of action: 2 (expected)
Current situation
The profession is regulated by title protection according to the Act on Psycholo-
gists
95
and reserves of activities.
Persons with a degree equivalent to the Danish degree in psychology can apply for
authorisation provided they have completed the supplementary two years of practi-
cal education after graduation and provided that they as a first have applied to the
Supervisory Board for recognition of their qualifications from abroad. Application
for authorisation also requires documentation for supervision received in connec-
tion with the psychologist’s work. Supervision received must amount to a total of at
least 160 hours.
Authorisation is not mandatory for the practice of psychology in Denmark, but it is
requested within certain areas of work. These areas include practicing psychology
under contributor number according to agreement on psychological assistance
96
,
and assisting in child protection examination according to article 50 in the Act on
Social Services.
97
95
96
Consolidated Act no. 229 of 8 March 2012
95
, article 1
http://www.dp.dk/wp-content/uploads/praksisoverenskomsten_11_14.pdf
Act no. 1053 of 8 September 2015
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97
Consolidated
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The objective of the regulation is to protect consumers and recipients of services. At
the legislative level, measures are in place to minimise the risks of misleading the
general public in the pursuit of the profession authorised psychologist.
The 2 years' authorisation scheme that is required in order to become an author-
ised psychologist ensures a high level of applied psychology, as the psychologist
under the license training receives guidance on the practical work of a more experi-
enced authorised psychologist. The measure includes a protection at the legislative
level in order to minimise the risks of misleading the general public in the pursuit
of the profession authorised psychologist. Furthermore, the Danish Supervisory
Board of Psychological Practice supervises the professional work of authorised
psychologists in Denmark. The board handles complaints of the work carried out
by authorised psychologist, but the board may also on its own initiative take neces-
sary action against an authorised psychologist.
Unauthorised use of the professional title "authorised psychologist" is punishable
by fine according to the regulation.
New situation/actions
In 2013, the profession was examined by a governmental task force (established as
a part of the Governments’ competitiveness policy package from 2012) in order to
identify simplification potential. It was proposed to create a more clear and simple
application process including digitalisation of the application process. This work
has been launched, but has not been completed. No further actions have been
planned.
Time frame
The work has been launched, but there is no specific timeframe at the moment.
Danish Agency for Higher
Education
Psychologist (DA Psykolog – beskyttet titel)
Competent authority: The Danish Supervisory Board of Psychological Practice
Cluster category: Health and social services
Type of action: 5
Current situation
The profession is regulated by title protection (without reserves of activities) ac-
cording to the Act on Psychologists
98
. Only persons who hold a Master’s degree
level in Psychology or persons who hold an equivalent degree from a university or
another institution of higher learning abroad are entitled to make use of the title
Psychologist. In Denmark, the degree is a general degree which gives access to work
within all areas of psychology. This means that specialised foreign degree holders
who have only studied certain areas of psychology are not immediately entitled to
make use of the title Psychologist in Denmark, as these degrees do not equate to the
Danish Master’s degree level in Psychology.
98
cf. Consolidated Act no. 229 of 8 March 2012
98
, article 21
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Psychology is the scientific study of psychological processes and behavior and use
of this knowledge in various areas of human life. The protection of the profession
title psychologist must be interpreted accordingly.
The objective of the regulation is to protect consumers and recipients of services. At
the legislative level, measures are taken to minimise the risks of misleading the
general public in their pursuit of the profession psychologist. Thus, a person who
does not have a university degree in psychology from an institution of higher edu-
cation in Denmark or abroad is not entitled to use the profession title "psykolog".
Unauthorised use of the professional title "psychologist" is punishable by fine ac-
cording to the regulation.
New situation/actions
In 2013, the profession was examined by a governmental task force (established as
a part of the Governments’ competitiveness policy package from 2012). It was con-
cluded that there is no proposal for simplification potential/improvement for the
profession. No further actions have been planned.
Danish Agency for Higher
Education
Cluster 2 – NETWORK SERVICES
Water Service Manager (DA – Driftsleder på renseanlæg)
Competent authority: The Danish Nature Agency
Cluster category: Network services
Type of action: 2 (expected)
Current situation
The profession is regulated by education, so that running a wastewater treatment
plant is only possible if you have got the right education, according to the regula-
tion, as
Management Assistant.
The authorisation gives the person in question the right to run a wastewater treat-
ment plant. The license is obtained by persons who have received a special educa-
tion. The objectives with the regulation are public health, protection of consumers
and recipients of services and protection of the environment and the urban envi-
ronment, including town and country planning. Regulation is thus based on the
fact that running a wastewater treatment plant is associated with significant risks if
it is not handled in a professional and skilled manner. The consequence of improp-
er or inadequate handling of the cleaning facility can result in serious safety and
health problems for people and the employee as well (i.e. the working environ-
ment) when getting in touch with the polluted water. The requirements make sure
that the water service manager has the necessary qualifications to make decisions
based on qualified and educated grounds and that the person in question knows
how to act correctly according to the relevant national legislation.
New situation/ actions
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In 2015 it has been decided that the current regulation in 2016 should be generally
revised to make sure that it is up-to-date and – if possible – more simple. The regu-
lation
99
has not been changed since 2007.
Time frame
The revision of the regulation will take place in 2016.
Training of operators and staff employed at landfill sites (DA – Ud-
dannelse af ansatte på deponeringsanlæg/ledere på deponeringsan-
læg)
Competent authority: The Danish Environmental Protection Agency
Cluster category: Network services
Type of action: 5
Current situation
The profession is regulated by reserves of activities cf. the Ministerial Order on
Training of Employees at landfills
100
. All employees at Danish landfills shall obtain
either an A-Certificate (landfill operators) or a B-Certificate (other employees). The
certificate gives the right to work at a landfill site. It takes between nine days to
eleven days to obtain the certificates.
The objective with the regulation is to ensure correct operation and safe handling of
the waste at the landfill. Thus, the requirements make sure that employees have the
necessary qualifications to work at landfill. The Danish Environmental Protection
Act
101
and the Ministerial Order on Training of Employees at Landfills
102
aim to
maximise the protection of the environment and the urban environment in regard
to landfilling and, at the same time, minimise the risks regarding the safety of the
employees and public health.
The nature as well as the complexity of the activities covered by the Ministerial
Order on Training of Employees at Landfills
103
both, to a high degree, imply that in
order to reach the objectives, it is essential that the activities are exclusively per-
formed by individuals possessing the professional qualifications set out in the or-
der.
New situation/ actions
No actions are foreseen at the moment.
Danish Agency for Higher
Education
99
Ministerial
Order no. 1446 of 11 December 2007 on the teaching of staff who operates wastewater
treatment plant
100
Ministerial Order no. 718 of 24 June 2011
101
Act
no. 1317 of 19 November 2015
102
Ministerial
103
Ministerial
Order no. 718 of 24 June 2011
Order no. 718 of 24 June 2011
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Obtaining collector certificate (DA – Krav om opnåelse af indsamler-
bevis/Indsamlere)
Competent authority: Danish Environmental Protection Agency
Cluster category: Network services
Type of action: 4 (decided)
A collector of recyclable industrial waste must have the necessary professional,
technical and financial capacity to obtain a collector certificate. Companies that
seek to be recognised as a collector of recyclable industrial waste should have at
least one person employed with a valid collector certificate. If the collector in mul-
tiple locations (P) numbers where there are 10 employees or more, there must be at
least one person per P-number with a collector certificate. The collector certificate
is personal and is valid for five years after which it has to be renewed. The certifi-
cate is achieved by passing an online test. It is a multiple choice test with twenty
five questions and a time frame of one hour. The certificate test costs a fee. There
has to be at least one day between each trial of passing the test and a maximum of
ninety days from the first attempt. There are three chances to pass the test with
new questions for every test that is started. After passing the test, the person has
status as a person who has achieved collector certificate with respect to require-
ments on collection companies pertaining to registration in The Danish National
Waste Register. Moreover, collectors of recyclable waste must on demand e.g. show
evidence that the waste is delivered to the required treatment in a registered and
approved recycling facility. The objective with the regulation is to protect public
health and the environment.
New situation/ actions
In 2008, the Danish Government introduced a new requirement in the Environ-
mental Act
104
based on recommendations in a report on the organisation of the
waste sector: collectors of recyclable industrial waste must have the necessary pro-
fessional, technical and financial capacity to be approved as collectors of recyclable
industrial waste. This requirement is met by the implementation of appropriate
education by introducing a test. The requirement was implemented in the Ministe-
rial Order on Obtaining Collector Certificate
105
which became effective from 1 Jan-
uary 2015. No further actions have been planned.
Danish Agency for Higher
Education
104
105
Act no. 1317 of 19 November 2015
Ministerial Order no. 1326 of 10 December 2014
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Summary – Review of the Danish regulated professions
First, this section briefly lists all the regulated professions in relation to decided,
expected and none foreseen actions (A). Secondly, the decided and expected actions
will be categorised in relation to the categories introduced earlier (B).
A. Overview of the professions with actions decided, expected and
none foreseen.
Professions with actions decided
Auditor/accountant (DA – Statsautoriseret revisor)
Energy engineer (DA – Energikonsulent)
Measurement and control technologist (DA – Certificeret støjmåler)
Translator and interpreter (DA – Translatør og tolk)
Authorised Veterinary Nurse (DA – Veterinærsygeplejerske)
Security guard/ Warden (DA – Vagtvirksomhed)
Security guard/ Warden (DA – Autoriseret kontrollør ved bestemte idrætsbegivenheder)
Certified Building Expert (DA – Beskikket bygningssagkyndig)
Well driller (DA – Brøndborer)
Electrical Contractor (DA – Elinstallatør)
Gas, Plumbing and Sanitation Fitter (DA – Gas-, vand- og sanitetsmester (vvs-installatør)
Sewage contractor (DA – Kloakmester)
Nine Off shore-professions (DA – Arbejde på offshoreanlæg)
Real Estate Agent (DA – Ejendomsmægler)
Harbour Pilot (DA – Lods)
Primary school teacher (DA – Folkeskolelærer)
Pedagogues in 1st–3rd grade (DA – Pædagog i børnehaveklasse–3. klassetrin)
Driving instructor (DA – Kørelærer)
Financial advisor (DA – Finansiel rådgiver)
Average Adjuster (DA – Dispachør)
Obtaining collector certificate (DA – Krav om opnåelse af indsamlerbevis/Indsamlere)
Danish Agency for Higher
Education
Professions with actions expected
Surveyor (DA – Landinspektør)
Four types of inseminator professions (DA – fire inseminørerhverv)
Rat controller (DA – Rottebekæmpelse)
Structural Engineer (DA – Anerkendt statiker)
Lift inspection (DA – Elevatoreftersyn)
Work with mobile cranes and tower cranes (DA – Arbejde med mobil- og tårnkraner)
Certified Pyrotechnician (DA – Festfyrværker)
Insurance Intermediary (DA – Forsikringsformidler)
Psychologist (DA
Autoriseret psykolog)
Water Service Manager(DA – Driftsleder på renseanlæg)
Fertiliser sample expert (Professional user of pesticides) (DA – sprøjtecertifikat)
Vermin controller (Persons using gas for vermin control must be licensed)/ (DA – Skadedyrs-
bekæmper (desinfektør)
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Professions with no foreseen actions
Lawyer/ barristor/ solicitor (DA – advokat)
Trikinseeker (DA – Trikinsøger)
Veterinary Technician (DA – Veterinærtekniker)
Veterinary Surgeon (DA – Dyrlæge)
Worker in mink farms (DA – Erhverv i pelsfarme)
Implantation of transponders in equidae (DA – ID-mærkere af dyr af hestefamilien)
Doorman (DA – Dørmand i virksomheder med alkoholbevilling)
Chimney sweep (DA – Skorstensfejer)
12 profession under the Danish Working Environment Authority
Eight Offshore-professions (DA – Arbejde på offshoreanlæg)
Commercial diver (DA – Erhvervsdykker)
11 maritime professions (DA – 11 erhverv inden for det maritime område)
Pet shops (DA - Dyrehandler)
Four professions under the Danish Emergency Management Agency (DA – fire erhverv under
Beredskabsstyrelsen)
Teacher, Danish Language Training Programmes for Adult Foreigners (DA – Lærer i dansk
for voksne udlændinge)
Upper secondary school teacher (DA – Lærer i de gymnasiale uddannelser)
Rearing of certain types of animals (persons responsible for rearing deer/ratites/foxes and
feathered game) (DA – Opdræt af visse dyrearter: hjortedyr, strudsefugle, ræve og fjervildt)
Farmer of genetically modified crops (DA – Dyrker af genetisk modificerede afgrøder)
Authorised Slurry Tank Inspector (DA – Autoriseret gyllebeholderkontrollant)
Investment advisor (DA – Investeringsrådgiver)
Responsible actuary (DA – Ansvarshavende aktuar)
23 health professions under the Danish Patient Safety Authority (23 erhverv under Arbejdstil-
synet)
Psychologist (DA – Psykolog – beskyttet titel)
Training of operators and staff employed at landfill sites (DA – Uddannelse af ansatte på de-
poneringsanlæg/ledere på deponeringsanlæg)
Zoological Taxidermist (DA - Zoologisk konservator)
Danish Agency for Higher
Education
B. Categorisation of the decided and expected
106
actions
Category 1-3 is deregulation that is introduced to make it easier to get access to
work as a professional. Category 4 is further regulation. Some of the professions are
listed in more than one category.
1. Abolishment of the scheme, change of rules and requirements, change in re-
served activities
Auditor/accountant (DA – Statsautoriseret revisor): Change of rules and simplification of
system
Surveyor (DA – Landinspektør): Reform of restriction on ownership of land surveying com-
panies
Translator and interpreter (DA – Translatør og tolk): The scheme will be removed/abolished
completely
106
As per 18 December 2015
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Authorised Veterinary Nurse (DA – Veterinærsygeplejerske): Allowed to do more tasks that
would otherwise be preserved for veterinary surgeons.
Certified Building Expert (DA – Beskikket bygningssagkyndig): Abolishment of the rules con-
cerning the building experts’ maximum price for a report.
Three professions in the Electrical, gas, plumbing and sewer fields: Overall simplification of
the authorisation scheme – introduction of part-authorisation scheme
Offshore-professions (DA – Arbejde på offshoreanlæg): Eight offshore professions are no
longer categorised as regulated professions
Certified Pyrotechnician (DA – Festfyrværker): An analysis of how to lower the educational
requirements has been launched
Real Estate Agent (DA – Ejendomsmægler): Buyer-counselling is no longer a reserved activity
Primary school teacher (DA – Folkeskolelærer): It is now possible for staff with different
training and qualifications to be included in the organisation of teaching of pupils
Average Adjuster (DA – Dispachør): From 1 January 2016, the current system will be re-
moved without replacement.
Danish Agency for Higher
Education
2. Change of administration, further digitalisation, simplified guidance,
modernisation etc.
Surveyor (DA – Landinspektør): Better opportunities in relation to the education and transfer
of credits
Measurement and control technologist (DA – Certificeret Støjmåler ): Simplification in rela-
tion to obtaining the certificate
Four types of inseminator professions (fire inseminørerhverv): Simplification of the system in
order to lift the administrative burdens
Security guard/ Warden (DA – Vagtvirksomhed): Specification of documentation require-
ments
Rat controller (DA - Rottebekæmpelse): Modernisation
Vermin controller (Persons using gas for vermin control must be licensed)/ (DA – Skadedyrs-
bekæmper (desinfektør): more digitalisation
Certified Building Expert (DA – Beskikket bygningssagkyndig): Digitalisation of the building
experts work will be implemented to make the scheme more effective
Structural Engineer (DA – Anerkendt statiker): The system will be modernised by introducing
a certification system that is more comprehensive and flexible than the existing one
Well driller (DA – Brøndborer): Modernising of the education to keep up with the technologi-
cal development in the field
Three professions in the Electrical, gas, plumbing and sewer fields: Overall simplification of
the authorisation scheme (introduction of a single company authorisation scheme)
Lift inspection (DA – elevatoreftersyn): Introduction of a new and simplified version of the
education
Work with mobile cranes and tower cranes (DA – Arbejde med mobil- og tårnkraner): Simpli-
fication and merger of six different crane certificates
Certified Pyrotechnician (DA – Festfyrværker): Approvals and licenses within the area of fire-
works will be combined in a common application system
Fertiliser sample expert (Professional user of pesticides) (DA – sprøjtecertifikat): mordernisa-
tion and further digitalisation
Habour Pilot (DA – Lods): Simplification and electrification in documentation
Insurance Intermediary (DA – Forsikringsformidler): Modernisation of the insurance inter-
mediary education.
Psychologist (DA – Autoriseret psykolog): To create a more clear and simple application pro-
cess including digitalisation of the application process.
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Water Service Manager (DA – Driftsleder på renseanlæg): Modernisation of the regulation
3. Merger of schemes
Auditor/accountant (DA – Statsautoriseret revisor): Merger of two professions into one
Four types of inseminator professions (fire inseminørerhhverv): Merger of educations and au-
thorisations
Three professions in the Electrical, gas, plumbing and sewer fields: Overall simplification of
the authorisation scheme: merger of schemes
Work with mobile cranes and tower cranes (DA – Arbejde med mobil- og tårnkraner): Simpli-
fication and merger of six different crane certificates
Two offshore professions have been merged and therefore consist of one regulated offshore
profession/skill. In the future, the profession is called ‘responsible for drilling operations (well
control course)’
Danish Agency for Higher
Education
4. Further regulations
Auditor/accountant (DA – Statsautoriseret revisor): The educational requirements are
strengthened
Energy engineer (DA – Energikonsulent): A new education has increased and sharpened the
required entrance qualifications + refreshing course and exam every third year in order to up-
hold their certificate
Authorised Veterinary Nurse (DA – Veterinærsygeplejerske): The non-authorised nurses are
allowed to do fewer tasks
Vermin controller (Persons using gas for vermin control must be licensed)/ (DA – Skadedyrs-
bekæmper (desinfektør): more control related to the reserved activities
Security guard/ warden (DA – Autoriseret kontrollør ved bestemte idrætsbegivenheder): Dis-
pensation from the education criteria is only given when the applicant without doubt is quali-
fied.
Pedagogues in 1st–3rd grade (DA – Pædagog i børnehaveklasse–3. klassetrin): The profession
has become regulated because it is considered necessary to use the pedagogical professional-
ism in teaching pupils in primary school
Driving instructor (DA – Kørelærer): A number of new requirements have been introduced
Financial advisor (DA – Finansiel rådgiver): The regulation was introduced in 2014 to mini-
mise the risk of consumers making decisions regarding financial products
Obtaining collector certificate (DA – Krav om opnåelse af indsamlerbevis/Indsamlere): Edu-
cational requirements were implemented on 1 January 2015.
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Chapter 3 – Conclusion
This final Danish Action Plan reports on the regulated professions included in both
the first and second cluster indicating the screening process of the regulated
professions and measures Denmark has taken or intend to take relating to the
transparency exercise making it easier to work as a professional. The exercise took
place in accordance with Communication from the Commission, COM (2013) 676,
dated 2. October 2013
107
and article 59 of the revised directive
To sum up, the first chapter in the report has described the process Denmark has
been going through in relation to the transparency exercise. It has highlighted the
fact that a governmental task force for regulated professions was established in
2013 as a part of the Government’s competitiveness policy initiatives. The task
force initiated a screening process of the regulated professions. This process has
resulted in deregulation, modernisation and simplification initiatives of a number
of the regulated professions. Some initiatives to remove regulatory restrictions
were already being taken when the task force was established.
Furthermore, Denmark has participated in the ongoing Frontrunners initiative on
professional qualifications in collaboration with a number of other EU member
states. In relation to the political initiatives of the Nordic Council of Ministers,
freedom of movement is an important agenda for the Nordic countries and these
countries have agreed to work towards removing cross-border obstacles, in particu-
lar the informal ones, e.g. industry regulation, in order to create jobs and growth in
the Nordic region.
The second chapter in this national action plan has included a review of all the
Danish regulated professions (both cluster 1 and 2) and has concluded on the
patters in the actions taken/to be taken.
To conclude, the review has shown that about a third (approximately 44 out of 120
of the Danish regulated professions recently have been going through changes or
are expected to do so in the near future. The actions primarity include deregulation
in the form of lift of reserved activities, simplification, modernisation, mergers,
further digitalisation etc.
For 78 professions, the competent authorities find that the current measures
related to the overriding reasons of general interest such as safety and health
should not be removed. Therefore, no actions are currently foreseen for these 78
professions.
It is worth highlighting that for two professions, Average Adjuster (DA –
Dispachør) and Translator and interpreter (DA – Translatør og tolk), the schemes
will be removed/abolished completely. Furthermore, three new professions have
had completely new regulation introduced: Financial advisor (DA – Finansiel
rådgiver), Obtaining collector certificate (DA – Krav om opnåelse af
indsamlerbevis/Indsamlere) and Pedagogues in 1st–3rd grade (DA – pædagog i
børnehaveklasse – 3. Klassetrin.
Danish Agency for Higher
Education
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Communication from the Commission to the European Parliament, the Council and the European
Economic and Social Committee on Evaluating national regulations on access to professions,
COM(2013) 676 final, dated 2. October 2013
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National Action Plan for regulated professions - DENMARK
Proportionality of the legislative acts regulating access to and exercise of the
regulated profession is subject to regular control of all draft legislation in Denmark
and has been evaluated again as a part of the transposition process during 2015.
By January 18 2016, Denmark shall also notify to the Commission the list of
professions for which a prior check of qualifications remain unchanged under
Article 7(4) and will provide justification of the inclusion of those professions on
that list.
Danish Agency for Higher
Education
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71/71