An employee may perform skilled tasks for years while, in documents and salary discussions, remaining a person without formally recognized qualifications. The exam is an opportunity for them to confirm their skills, change their professional position and plan the next step. What happens to that opportunity when, after obtaining the certificate, they face months-long waiting?
In the article "A Skilled Worker on the Job, an Assistant on the Payslip? We Ask HK-dir", published on 13 October, we announced that we would check reports of the suspension of some proceedings. Since then Radio Wataha and TwojaNorwegia have received letters, correspondence and responses from Norwegian institutions and the Polish chamber.
The most important finding is clear: HK-dir itself confirmed the legality of the described practice of D&A Spesialistene and the validity of Polish certificates. At the same time, some applications remain pending while the rules for their recognition are being clarified.
There is no simple equation "exam passed, Norwegian document granted." There is, however, a concrete question: how long must a worker bear the consequences of uncertainty about the path that the Norwegian authority previously accepted?
What exactly did HK-dir write about D&A?
In a letter to Kunnskapsdepartementet dated 29 June 2026, ref. 26/13834-1, HK-dir states:
"The practice of D&A Spesialistene is legal, and vocational and journeyman certificates are valid according to Polish regulations."
In the editorial translation: "The practice of D&A Spesialistene is legal, and vocational and journeyman certificates are valid according to Polish regulations."
The authority goes on to write that according to the rules in force at the time it saw no basis for refusing or treating such certificates specially, and that they were considered equivalent to the Norwegian fag- and svennebrev. It also explains that it received confirmation that the exams comply with Polish law, and that Udir assessed that organizing them in Norway does not violate the opplæringslova.
This position concerns the described examination practice. It is not an accreditation of all the company's services nor a guarantee of a positive decision for every candidate. D&A organizes access to the exam; the commission of the Polish chamber examines and issues the Polish certificate; HK-dir considers the application for recognition of the specific qualification.
Why is a legal certificate still waiting?
The ministry, in a response to the editorial office, explains that it is examining the general question: whether the system for recognition of foreign vocational education also covers qualifications obtained on Norwegian territory through foreign examination paths for candidates taking exams outside the standard course of education.
"The department has not asked HK-dir to pause individual cases."
That is: "The ministry has not asked HK-dir to suspend individual cases."
Kunnskapsdepartementet confirms that it is aware of HK-dir's waiting for a decision on some applications. It promises an answer "soon" and that it will be available under the access to documents procedure. In the reply provided to the editorial office it does not give a specific deadline. The ministry decides on the matter of interpretation, not on individual employees' applications.
The question therefore also concerns the significance of the place where the document was obtained. If the certificate is issued by an authorized Polish chamber, and the exam is subject to Polish rules, what does the fact that it was conducted in Norway change for the assessment of its equivalence? If this circumstance has legal significance, the employees and the organizer should receive a clear explanation.
Updating assessments was also a cause of delays
The full picture requires taking into account the response from HK - dir of 16 October, ref. 26/21334-3. The authority indicates that some earlier bases for assessing qualifications required updating relative to the Norwegian Vg3 programs after the reform. In some professions it also did not rely on the latest available Polish program from 2019.
HK - dir cites remarks from the appeals committee about the need for greater transparency and the ability to verify assessments. The update began in the second quarter of 2026; for most of the qualifications covered it was completed in week 41, that is 5 - 11 October. Legal questions were being clarified in parallel.
It would therefore not be fair to attribute all the delays to a single phone call, video or appearance by an industry organization. The authority describes two overlapping processes. The question remains: which decisions can already be resolved after the completion of the professional assessments, and which still require a response from the ministry?
HK - dir also confirms that there is no single separate written decision nor a single instruction introducing the suspension of the entire group of cases. It describes internal determinations, including the decision of 26 June to approach the ministry and the information conveyed on 10 September at a staff forum about awaiting an interpretation. The mere absence of a separate document does not determine illegality. However, it justifies the expectation of clear information about the scope, basis and expected end of the waiting period.
Hundreds of unfinished cases, thousands of earlier recognitions
In a letter of 15 October the ministry cited a telephone report from HK - dir: as of 9 September it concerned more than 200 but fewer than 400 suspended cases. That is a historical estimate.
A newer HK - dir summary includes 417 cases not yet assigned for handling and 21 started but not completed. The oldest come respectively from 11 April and 2 March 2026.
The total number 438 is an approximation concerning unfinished cases found by the label "Chamber" as the issuer. It is not a confirmed number of blocked D&A clients. HK - dir cautions that the summary may include other pathways and omit some proper cases. The filing dates of the oldest applications do not determine the dates when their suspension began.
At the same time, in correspondence with the ministry from 8 - 9 October HK - dir reports over 2,400 recognitions among applications registered since the beginning of 2023, concerning Polish qualifications obtained from 2023 by craft chambers. The authority cannot precisely separate exams conducted in Poland from those passed in Norway. The number covers a broader group than clients of a single organizer.
We are therefore dealing with a previously operating administrative practice. People could take it into account when making decisions about the exam, expenditures and their further professional life. How will that trust be treated?
What exactly does an exam in Polish give the worker?
D&A Spesialistene organizes the opportunity to take the Polish journeyman's exam in Norway in cooperation with the chamber in Radom. The arrival of the examination board, organization of the venue and candidate services reduce the barriers related to traveling to Poland and the exam language.
The value of this initiative can also be assessed socially. For an experienced worker, the opportunity to test their knowledge in a comprehensible language can be the beginning of further development. Formal confirmation of competencies provides an argument in employment discussions, the prospect of further qualifications and the sense that many years of practice have been recognized. It does not guarantee a pay raise or recognition by HK - dir, but it may open the way to both.
The Polish exam does not mean the theory is omitted. The chamber describes an independent practical part and written and oral theory. Among other things, vocational knowledge, documentation, drawing and safety rules are checked. Information about candidate materials is available on the chamber's website. We also asked directly about the detailed scope of preparation, the materials provided and the method of verifying experience.
This should not be called the only existing route. Norway offers praksiskandidatordningen, fagbrev på jobb and adult education. Formal availability, however, does not mean equal accessibility for every working person. Norwegian trade tests take place in Norwegian, Sami or Norwegian sign language. The language barrier can make it difficult for a person who is only learning Norwegian to demonstrate vocational knowledge.
Language learning and confirming existing skills can progress in parallel. An exam in Polish does not replace knowledge of safety rules, workplace communication and locally required authorizations. However, it can allow a person to take the next step before achieving language fluency.
Poland already responded in 2024. Now it is preparing a more complete position
In November 2024 HK - dir corresponded with the Polish Craft Association. ZRP confirmed that the described exams of the Radom chamber in Norway comply with Polish procedures and regulations and informed that the matter was consulted with the Ministry of National Education. This is not merely an argument presented after the current editorial intervention.
On 20 October 2026 the chamber in Radom replied to us that its lawyer is preparing an official letter to HK - dir, including, among other things, the legal basis for the exams. It announced it would provide the letter along with explanations. The final position is not yet included in the material made available to us.
You can work. But what about pay?
The Ministry emphasizes that the system is a voluntary, free tool for making competencies visible and that without recognition by HK - dir one can work in Norway. In non-regulated professions this is important information. Regulated professions have separate requirements concerning authorizations.
However, the ability to continue working does not resolve the question of the wage rate. In a response to the editorial office, approved for citation as the position of section manager Tonje Faanes, Arbeidstilsynet explains:
“Until such recognition is granted, the employee will, in principle, be covered by the rates for unskilled workers.”
In the editorial translation: until recognition is obtained, the worker as a rule is subject to the rates for unskilled persons. The answer concerns the regulation on generally applicable minimum conditions in construction.
According to the rates published by Arbeidstilsynet and checked on 27 October 2026:
Construction category
Minimum gross per hour Skilled worker - fagarbeider264,32 NOK
Without formal qualifications, with at least one year of industry experience249,00 NOK
Without qualifications and without industry experience239,61 NOK
Between the first two rates there is 15,32 NOK per hour. For an example 162.5 hours per month the difference amounts to 2489,50 NOK gross. This is an illustration of the difference between the minimums, and not a calculation of the actual loss for each applicant. An employment contract and collective agreement may provide more favourable conditions.
Arbeidstilsynet notes that the regulation itself does not provide automatic compensation for the period before the recognition of the document. The employer may also pay more before a decision is made.
That is precisely why the sentence “you can continue to work” does not close the matter. Waiting may have a cost that a later positive decision will not remove.
Industry organisations ask about quality. Workers have the right to ask about a remedy
The documents show interest from Fellesforbundet, NHO Byggenæringen, EBA and the professional council for construction. Reservations concern the scope of the exams, competencies, safety and trust in the recognised qualifications.
In March 2026 NHO Byggenæringen and Fellesforbundet requested an evaluation of the system. The ministry replied on 24 March that it did not then plan another evaluation. It pointed instead to studies on the impact of recognising foreign education on the labour market and social mobility. The organisations’ June request for a meeting covered both recruitment of skilled workers and the quality of recognised foreign qualifications.
Archived correspondence of the council also shows that in spring 2025 the expansion of the system to include two new professions was postponed due to doubts regarding Polish exams. That decision should not be equated with the later suspension of individual applications.
The October document concerning the SMS to LO cites Fellesforbundet’s position that foreign certificates should be able to be recognised while maintaining a comparable level. It does not contain an order to stop cases nor evidence of an intention to maintain lower wages.
Protecting standards is a legitimate objective. The question is what specific findings result from it: what is missing in a given qualification, how was this documented and what can the worker do? In separate correspondence there are also unverified reports concerning another organiser and another chamber. They cannot be transferred to D&A and the chamber in Radom.
Is this discrimination? LDO has not issued such a decision
The jurist of Likestillings - og diskrimineringsombudet, Elida Steinsdatter Andersen, explained to the editorial office that LDO provides guidance regarding the regulations, while the adjudication of complaints belongs to Diskrimineringsnemnda.
In its response, LDO did not rule that discrimination had occurred. It noted that it did not sufficiently know the grounds and the scale of the suspension. It also explained that differentiation related to origin may be lawful if it has an objective purpose, is necessary and proportionate.
At the same time, it pointed to the social dimension of the problem:
the lack of recognition of foreign education can create barriers for people with foreign backgrounds to participation in working life.
That is: the lack of recognition of foreign education can create barriers to participation in the labor market for people with foreign backgrounds. LDO emphasizes that the problem may be adverse from the perspective of equal opportunities even when it does not legally constitute discrimination.
Norway needs skilled workers. Can it retain their ambitions?
In NAV's 2026 study, the shortage of workers was estimated at 34,000 people, including 4,750 in the construction occupations group and 5,750 in industry. This is an estimate from an employer survey, not a current vacancy counter or confirmation of each candidate's qualifications. However, it shows that even in difficult market conditions companies report a demand for people with the appropriate skills.
At the same time, SSB reports that in 2025 10,500 new labor immigrants arrived from outside the Nordic countries — the fewest since 2005. 1,820 of them were from Poland. The data do not in themselves confirm that an increasing number of Poles are leaving nor that decisions of HK - dir are the cause of departures. They do, however, confirm a low inflow of new workers.
This raises the question of Norway's interest: how to make use of the skills of people who already live here, work here and want to develop?
Long-term uncertainty may discourage further effort. This is a risk, an unmeasured effect in this case for the entire Polish community. It is worth taking it into account before the prospect of promotion is replaced for months by a message of waiting.
Contribution of D&A and Wataha: access to the exam, information and responses
D&A creates the organizational conditions for access to the Polish exam in Norway. Wataha and Twoja Norwegia describe this possibility, explain the procedures and request documents and responses. These are two different types of contributions to the accessibility of professional development: organizational and informational.
Our intervention made it possible to determine who is waiting for an interpretation, how the office describes the delays and what significance waiting may have for wages. We do not attribute to it any influence on the outcome of the proceedings — such a result has not yet been presented to us.
As an editorial office we must also disclose our own presence in the documents. In correspondence from 2024, Fellesforbundet cited a description of D&A posted on Wataha.no. The quoted passage contained an imprecise reference to the Norwegian certificate and information about declaring experience. This wording requires clarification of its authorship, its wording at the time, and the actual procedure for verifying practice. Responsibility for verifying a candidate's documents must be established specifically.
Separately, HK - dir in a letter dated 28 June 2026 drew attention to a film and D&A's communications, which, in its view, could suggest cooperation or endorsement by the agency. The letter concerned the presentation of HK - dir's role; it did not annul certificates and did not prohibit examinations. Without analysing the referenced film and the organizer's response, we do not determine whether the allegation was well founded.
The correct message is simple: a Polish certificate may be individually assessed by HK - dir. The agency does not approve the organizer, the course or the examination package. Such precision should also be maintained when showing the social value of the initiative.
A path that a worker can follow is needed
Section 23-3 of the opplæringslova provides for recognition of education that meets the requirements of level, scope and many essential elements of a given profession. An important Polish certificate does not grant automatic recognition, but the worker should receive an assessment according to clear criteria. In the previously cited case 2026/0720 the appeals committee overturned HK - dir's refusal and referred the case for reconsideration. That was not a collective ruling concerning D&A. It shows the importance of the possibility to have a decision reviewed.
We expect a solution that will preserve standards and support development. HK - dir, the ministry, the Polish chamber, organizers, employers and employee representatives can clarify the requirements and determine which documents reliably confirm competencies. Such a dialogue does not mean a promotional partnership of the agency with a company nor a guarantee of recognition.
Concrete answers are needed:
What exactly is the scope of the suspension and when will a decision be made?
Which applications can be concluded after the professional assessments have been updated?
Is the deciding factor the content of the qualification, the way it was obtained, the place of the exam, or several of these factors?
How should the organizer and the chamber document experience and the course of the examination?
If there are gaps, is it possible to supplement them and who can indicate the appropriate path?
How will people who decided to take the exam in reliance on existing practice be treated?
How can the financial and social consequences of prolonged waiting be limited?
In our view, an initiative that helps working people confirm their knowledge deserves a matter-of-fact assessment and clear conditions for further action. Quality control should lead to an outcome from which the candidate understands what they have fulfilled, what they lack and what options they have.
We still do not understand why clarifying the rules must leave workers in uncertainty for so long. We understand the need for standards. However, we also need a comprehensible path for those who want to meet them.
If integration is to mean work, language learning, development and building a future in Norway, it must also include the possibility of seeing the result of one's own effort. Where is that possibility for a person who legally passed the exam and still does not know when they will receive a decision?
Status of the material: 27 October 2026, based on documents and responses provided to the editorial office. This set does not include the ministry's final interpretation nor the announced legal position of the chamber in Radom. Polish quotes from Norwegian correspondence are translations by the editorial office.
Update — 27 October 2026
We received a response from HK-dir dated 23 October. The agency confirms that the mere taking of an exam in Norway is not a basis for refusing recognition of qualifications, and information obtained from Polish institutions did not indicate that the examined exams violated Polish requirements. However, the validity of a certificate does not imply automatic recognition - the level, scope and content of the qualifications are still assessed. HK-dir also reports a suspension of processing of cases of candidates from the practical pathway regardless of the place where qualifications were obtained. The exact scope of this statement requires clarification: the letter does not make clear which countries and professions are covered. According to the agency, most updated professional assessments were completed in weeks 41 - 43, but at the time the response was prepared they were still awaiting the ministry's interpretation and no deadline for concluding the cases was given. HK-dir notes that any change in practice will not affect the outcomes of decisions already issued. For waiting workers the fundamental question therefore remains: when will they receive a decision and what specific requirements must they meet?
Sources of information for the publication
HK-dir, letter to Kunnskapsdepartementet dated 29.06.2026, ref. 26/13834-1, pp. 1–6.
Kunnskapsdepartementet, press response for Radio Wataha conveyed by Martin Siewartz Nielsen; quote attributed to the ministry.
HK-dir, response to the editorial office's request for access to documents, 16.10.2026, ref. 26/21334-3.
Kunnskapsdepartementet, response to the request for access to documents, 15.10.2026, ref. 26/4899-2.
Correspondence between HK-dir and Kunnskapsdepartementet from 8–9.10.2026, in files 26/13834-2.
Chamber in Radom: journeyman exams, materials for candidates, ZRP: examination standards.
Udir: vocational exams; trade certificate at work.
Correspondence between HK-dir and ZRP from 11–18.11.2024, the Polish original and translation provided by HK-dir.
Chamber in Radom, email response to the editorial office dated 20.10.2026.
[ Arbeidstilsynet, press response to the editorial office, authorized attribution: section leader Tonje Faanes.
[ Arbeidstilsynet: minimum wages and § 4 of the construction regulation, accessed 27.10.2026.
Kunnskapsdepartementet, letter to NHO dated 24.03.2026; NHO Byggenæringen/Fellesforbundet, request for a meeting dated 5.06.2026, case 26/2050.
Correspondence HK-dir/Udir/FRBA from spring 2025 and Udir from 8.01.2026, made available in files 26/21620-3; the material contains draft protocols.
Document "sms fra LO til statsråd Fugelsnes", entry to the ministry's archive dated 9.10.2026.
Correspondence HK-dir/ZRP concerning another organizer and the Lublin chamber, 4.04.2025 and 10.03.2026. Reports described as unverified, not as established violations.
LDO, response to the editorial office, authorized attribution: jurist Elida Steinsdatter Andersen.
NAV: Business survey 2026.
SSB: Lowest labor immigration in 20 years, updated 28.08.2026.
Correspondence Fellesforbundet/HK-dir from 29–30.10.2024, made available in files 26/21620-1.
HK-dir, letter to D&A dated 28.06.2026, ref. 26/13738-1.
Education Act § 23-3 — Udir and appeal committee, case 2026/0720.
