On December 10^th, 2021 the Commission presented the draft Council Recommendation on Individual Learning Accounts (COM/2021/773 final). This initiative originated from one of the 12 flagship actions of the European Skills Agenda, with the goal to "help close existing gaps in the access to training for working age adults and empower them to successfully manage labour market transitions". The topic is also related to the European Pillar of Social Rights Action Plan which sets the target of 60% of adults participating in training every year by 2030.

Eurocadres welcomes initiatives aimed at ensuring access to skills development and lifelong learning for all workers, as it resonates with our policy priority on strengthening a knowledge- based Europe. Investments in qualifications and skills are crucial to reach this goal especially in times of profound and far-reaching labour market changes due to the transition towards a green and sustainable economy and continuous digitalisation into all spheres of human life. However, an ILA is only one tool out of many other possible solutions to master the challenges ahead. Engaging in learning and education is a constant and continuous process adapting to changes which needs to correspond to required skills, qualifications, and competences throughout peoples’ lives.

Eurocadres is pleased to see that the draft recommendation confirms the crucial role of social partners in important aspects of the ILA including:

• design and setting up of ILA
• development of eligibility criteria for training providers and their training offers hence guaranteeing quality and relevance of training
• developing rules and criteria for career counselling
• developing rules and criteria for validation of previous skills
• developing of funding schemes
• developing of paid leave arrangements

Another important principle of the draft recommendation is the primacy of Member States’ competence together with the affirmation that well-functioning and established national systems should not be deteriorated or replaced by the creation of an ILA. Neither should it prevent from establishing more advanced provisions on adult learning. Eurocadres underlines the importance that an ILA is only one tool out of many other possible solutions on national level and thus, should have an added value to existing systems by improving, strengthening, and guaranteeing access, entitlements and rights to all categories of working-age adults.

However, Eurocadres would like to indicate that the focus on the individual should not shift the sole responsibility onto the individual to take care of his/her training needs but also to make and keep employers responsible for company-based employee training. Thus, it is of importance that the aforementioned principle of avoiding damage to existing systems must be safeguarded. Adult training and education are a shared responsibility between the individual, the employer, and the government.

Eurocadres is especially pleased to see that the target group of the initiative are all working- age adults independently of their education level and current employment status, hence including also self-employed, persons in atypical forms of work relations as well as unemployed. Eurocadres reminds that in some Member States the employee category of professionals and managers is even excluded from access to adult learning systems and entitlements because initiatives are centred around and designed for lower-qualified employees; professionals’ and managers’ careers are impacted by the digital and green transition and the need for new skills especially in leadership is obvious. Further, the recommendation should add, and hence, make it explicit that employees from all sectors including both private and public are entitled to an ILA.

It is important that the ILA allows for some flexibility adding training entitlements to specific groups with specific needs. This universal but differentiated approach would allow alteration of funding according to individual needs (based on the needs of a region, sector, SME’s, etc.). It is welcomed that theses alternations should be decided and put in place after having consulted with social partners.

The recommendation is limiting training to labour market relevant training. Certainly, it is important that individuals receive relevant and quality training which allows them to stay employable on the labour market as well as improve and foster individuals’ career paths. However, according to the current text the individual might not be able to choose what he/she may well consider as relevant for a professional career but nevertheless might not fit into the defined labour market needs. In order to make sure that the individual’s right of choice is not constrained it is of importance that the key actors, social partners and government, define together labour market relevant training.

Eurocadres is advocating for re- and upskilling of professionals and managers. Especially re- skilling requires a much more engaged and longer lasting training of the individual to transfer to another job or acquire another profession. Thus, the provision of accumulation of individual training entitlements is important and should guarantee a sufficient level/amount of accumulation to allow for longer and substantial training also for obtaining higher qualifications.

For up-skilling purposes micro-credentials, certified learning outcomes of short-term learning experiences, can be a good solution to be offered by training providers for skills assessments and formal and informal-learning opportunities as recommend in the draft document.

However, it should be guaranteed that micro-credentials lead to a meaningful improvement of an existing qualification and do not replace a full professional qualification as it is affirmed in the draft Council Recommendation on micro-credentials (COM(2021) 770 final) saying that “micro-credentials can be used to complement and enhance education, training, lifelong learning and employability ecosystems. They do not seek to replace or disrupt, initial, higher education, vocational education and training (VET), or traditional qualifications”.

The paragraph on paid training leave in the draft recommendation is very much welcomed which refers also to the ILO Paid Education Leave convention. The text could promote even stronger the implementation of the convention in all EU Members States. Paid training leave should correspond to the trainings offered, including long-term training and education resulting from accumulated training entitlements.

The ILA should be grounded on sound funding to avoid that the individual is forced to pay an own contribution. The recommendation is suggesting cost-sharing between public bodies and employers or arrangement resulting from collective bargaining agreements between social partners. As mentioned above it is important to respect existing national financial schemes and avoid weakening financial commitments.

Measures and provisions for quality testing of training providers and the training opportunities they offer is of high importance. Eurocadres welcomes that the recommendation foresees social partners being involved in formulating quality requirements as well as developing the means and tools for the recognition of theses quality requirements for training providers – in a transparent manner and in cooperation with relevant stakeholders.

Barriers for adults to take up training is not always linked to lack of time or finances it is also due to lack of career guidance and validation of prior learning. The recommendation is including these two principles as part of an enabling framework which are important drivers for motivating and reaching out to people. Social partners will play a key role in setting criteria for effective career counselling and for validation of sufficiently broad range of prior learnings as the foresights of labour market skills needs will become more complex as well as strategic planning of career paths.

A geographical transferability between Member States is not foreseen for now but will be explored at a later stage. Eurocadres regrets this delay because for professionals and managers, who are the most mobile category of employees in Europe, this restriction is very much unfavourable as well as for cross-border workers.

In the forthcoming negotiations in the Council on the draft Council recommendation on ILA Eurocadres calls the Members States:

• To guarantee a strong involvement of social partners in the setting up and the governance of national ILAs
• To strengthen and safeguard existing well-functioning adult learning systems by making ILA an added value to national systems
• To guarantee a large scope of the target group, including professionals and managers
• To avoid a narrow definition of labour market relevant training by allowing individuals to pursuit own career aspirations
• To make sure that the accumulation of individual training guarantees a sufficient level/amount of accumulation to allow for longer and substantial training also for obtaining higher qualification
• To guarantee that micro-credentials lead to a meaningful improvement of an existing qualification and do not replace a full professional qualification
• To set paid leave arrangement which fit long-term trainings and to promote the implementation of the ILO Paid Education Leave convention in all EU Member States
• To guarantee a sound ground of funding assuring full coverage of training costs
• To guarantee high quality of training and of training providers
• To guarantee quality career guidance and validation of sufficiently broad range of prior learnings