On construction sites, one can entrust a person with tasks that require experience and independence. When it comes to pay, the same person can still fall into the category of workers without formally recognized qualifications. If they presented a Polish journeyman's certificate, and the Norwegian authority does not decide their case for months, the company keeps the work going. For the worker, the prospect of a higher rate may be delayed. Is it fair that the state leaves the financial risk with the person whose competencies it wants to verify?
In the first article, “Skilled worker on the job, helper on the payroll? We ask HK-dir”, we asked about the scale and basis for the suspension of applications. In the second, “Legal exams, suspended promotion. What next for Polish skilled workers?”, we described the ministry’s position and the first responses from the authorities. Now we have documents that allow us to go further: HK-dir’s response to a request for access to the files, new comparisons of professional qualifications and detailed explanations from the Chamber of Crafts in Radom.
The strongest finding is stated explicitly. HK-dir does not have an assessment of the proportionality of the suspension nor of its economic consequences for applicants. For people waiting for a decision, this gap matters more than another declaration that the authority cares about quality.
What exactly has stalled?
A Polish journeyman's certificate and a Norwegian decision on recognition of qualifications are two different documents. The first confirms a qualification obtained under Polish rules. The second answers the question of whether it can be considered equivalent to the appropriate Norwegian fagbrev or svennebrev. In accordance with § 23-3 of the Norwegian Education Act, the level and scope of education are compared, and whether it includes many of the essential elements of the profession in question.
The ministry described the situation as follows: HK-dir observed an increase in the number of applications from people who shortly before submitting the application had obtained Polish qualifications through a practice-based procedure. The exam and the practical test often took place in Norway, according to Polish regulations. The directorate therefore asked whether the current system also covers qualifications obtained in Norway as part of a foreign pathway for candidates with experience. The ministry is to answer the general question; decisions in individual cases belong to HK-dir.
In a response approved for quotation, HK-dir department director Silje Molander said:
"That the test has been carried out in Norway is not in itself grounds for rejection."
The mere fact that the exam took place in Norway is not grounds for refusal. HK-dir also stated that information obtained from Polish institutions did not indicate that the examined exams violated Polish requirements. The agency indicates, however, that cases from the practical pathway are awaiting interpretation and that the issue goes beyond the mere location of the exam. The response does not include a full list of countries, occupations and cohorts covered by the suspension. HK-dir also noted that the awaited interpretation will not change the outcome of decisions already issued.
That distinction matters. It is possible to confirm the validity of a document in Poland while at the same time examining whether the qualification meets Norwegian conditions. It is also possible to determine that the exams require verification. However, each of these actions requires an answer to a separate question: why exactly was the suspension of this group of cases, to this extent and for so long, necessary?
From industry concerns to the suspension of cases
WhenWhat follows from the documents
Autumn 2024
Questions arise in the Norwegian industry about how the exams were marketed and how candidates' practice was checked. The Polish Craft Association confirms that the exams of the Radom chamber are held on the basis of Polish regulations.
Spring 2025
The Norwegian professional council postpones the expansion of the system to two occupations. This is a separate stage: it does not yet mean the suspension of individual applications.
March 2026
NHO Byggenæringen and Fellesforbundet publicly announce that they asked HK-dir to investigate the practice of D&A and call for a review of the system. They justify this with concerns about quality, safety and confidence in the qualifications. The ministry responds on 24 March that at that stage it does not plan another evaluation.
June 2026
The organizations ask the ministry for a meeting, among other things, regarding recruitment and the quality of recognized qualifications. HK-dir turned to the ministry on 29 June for an interpretation of § 23-3. The letter indicates that the resolution of some cases has already been suspended.
September 2026
According to information cited by the ministry on 9 September, there were more than 200 but fewer than 400 cases. That is an estimate from a specific day. HK-dir documents indicate that on 10 September the agency agreed to continue waiting for the interpretation.
October 2026
The ministry confirms that it did not order the suspension of individual cases. HK-dir reports that the location of the exam alone does not justify a refusal. It then releases updated occupational assessments and confirms the lack of an assessment of proportionality and the economic consequences for applicants. The chamber in Radom provides the editorial office with a description of the exams and the verification of documents.
Beginning of November 2026
After the transitional response of 30 October, HK-dir approves quotes for publication. On further issues it refers to the awaited interpretation. In materials available to the editorial office on 11 November there is no final position from the ministry nor a confirmed date for the resumption of cases.
The scale cannot be determined by subtracting the number of recognitions from the number of applications. The October files also contain the number 438: 417 cases without assignment and 21 assigned but unfinished cases found when searching by the certificate issuer. This is a different way of counting than the ministry’s September estimate. The result covers cases found according to the specified criterion, not a strict list of cases subject to the pause. It is also not a number of refusals. A fair answer to the question “how many people are actually waiting and how many were refused?” still belongs to HK-dir.
The industry had access to the agency. But who presented the worker’s costs?
The influence of industry organisations is not conjecture. The employers’ organisation NHO Byggenæringen and the trade union Fellesforbundet openly pushed for control of the D&A practice and a review of the system. HK-dir’s June letter indicates that signals from social partners, companies and the industry environment were among the reasons for taking up the topic. The ministry’s files also include an October note about a message from a representative of the LO central union concerning standards and trust in the system. That message comes from the period after the suspension began, so it cannot explain its start.
The industry has the right to demand reliable verification of exams. The union and the employers’ organisation declare that they are concerned with safety and quality, not with limiting professional mobility. The documents do not show that they ordered applications to be stopped or sought to lower the wages of Poles. HK-dir is responsible for the suspension of decisions.
The question of balance remains. If the industry’s reservations were enough to trigger a review, what weight did the voices of the people who were to bear the consequences of waiting carry? When did the agency ask the chamber about specific differences? Did it compare suspending the entire group of cases with continued individual assessment? Has anyone calculated how the lack of a decision may affect rates, changing employer and promotion opportunities?
In its response of 28 October, ref. 26/22242-2, HK-dir wrote:
“Furthermore, there is no assessment of proportionality or economic consequences for the applicants.”
In the editorial translation: there is no assessment of proportionality or economic consequences for applicants. The agency also did not identify separate documentation evaluating the necessity of the suspension beyond what was included in the inquiry to the ministry. This finding does not decide whether the agency’s actions were lawful. However, it shows what specifically should be asked of it: on what basis did it conclude that this manner of waiting for guidance is appropriate for all the cases it covered?
A specialist for the job, a rate for the unskilled: how does it work?
The ministry emphasizes that recognition in this system is voluntary and free of charge. The absence of an HK-dir decision in itself does not remove the possibility of working in an unregulated profession. That answers the question of whether a person can continue to work. It does not explain which rate they can claim or whether they can move to a position for which the company formally requires a recognised document.
Arbeidstilsynet explained to the editorial office that in construction covered by the regulation the right to the minimum for a skilled worker depends on an appropriate Norwegian certificate or a recognized foreign equivalent. Until recognition, a worker with a foreign document is, as a rule, subject to the minima for workers without such confirmed qualifications, taking seniority into account. Regulation in force since November 6 provides the following rates:
Category in construction covered by the regulationGross minimum per hourSkilled worker in the given profession (fagarbeider)276.48 NOKWorker without formal qualifications, with at least one year of experience in the industry260.45 NOKWorker without formal qualifications and without experience in the industry250.63 NOK
If we compare the first two rates, we get 16.03 NOK per hour, which is about 2605 NOK gross for 162.5 hours of work per month. In the October article we provided the then minima and the difference of 2489.50 NOK under the same assumption. This is a comparison of minimum rates, not a calculation of any individual’s loss. An employer may pay more, and an employment contract or collective agreement may provide more favorable conditions. As Arbeidstilsynet noted, the regulation itself does not automatically give the right to back pay for the period before recognition of qualifications. These rates should not be transferred to mechanics, cooks or other industries.
This is the problem. A worker may actually perform work that requires qualifications, while at the same time not yet have the basis to invoke the higher minimum arising from this regulation. That does not prove that a specific employer is breaking the law. It does show, however, how an administrative decision, or even the lack of such a decision, can affect what portion of the value of their work a person has a chance to recover in pay. Should a company that trusts a person enough to entrust them with independent skilled work wait for the authorities to fairly price their work?
What did D&A Spesialistene do and what did the chamber check?
D&A organized in Oslo the logistics for exams and access to materials for learning theory, and also helped participants with organization. This is concrete work: for a person employed full time who can perform the occupation but has not yet mastered Norwegian to the level needed to sit the professional exam, a Polish-language path gives a chance to demonstrate the competencies they already possess.
A letter from the Chamber of Crafts in Radom dated October 28 states that the chamber is responsible for admitting candidates, appointing the committee, the course and assessment of the exam, and issuing the certificate. It indicated that it checks documents confirming the scope and period of practice, and in certain cases the regulations provide for a candidate’s declaration. It described the theoretical and practical parts and materials helpful for independent study. According to its data, from November 2024 to September 2026 about 800 people passed in Oslo; the chamber also included retake exams. These are the chamber’s data about its exams, not the number of recognitions in Norway.
In 2024 industry correspondence there were questions about wording in announcements concerning the verification of practice and Norwegian recognition. Such questions are justified: a candidate should know who verifies the documents and what the certificate does not guarantee. HK-dir also drew D&A’s attention to the fact that the way the office visit was presented could suggest cooperation or endorsement. The authority emphasized that its representatives were observers, not partners in the exam. This is not a ban on organizing exams. The chamber pointed out, in turn, that it had not been given specific allegations regarding the quality of those exams. All the more reason for a discussion about the documents and standards that can be verified by both sides.
There is no need to announce that every certificate issued after an exam in Oslo provides a basis for Norwegian recognition in order to appreciate the organized opportunity there to confirm skills. HK-dir should treat this effort as a starting point for cooperation with the chamber, regional education authorities, industry representatives and employees. Wataha, by publicizing the issue and compiling institutions’ responses, wants to achieve exactly this: so that a person interested in development knows what they can do next.
What do the new opinions about occupations show?
The assessments released by HK-dir do not give a single answer for all Polish certificates. In comparisons with specific Norwegian occupations, qualifications such as concrete worker-rebar worker, carpenter and joiner were evaluated negatively in the examined scopes. In the case of the concrete worker-rebar worker, a convergence of some competencies was recognized, while differences were also indicated, among others, in planning and executing formwork and working with precast elements. In the case of the motor vehicle mechanic, the result was positive in comparison with the Norwegian occupation concerning light vehicles, and negative in the comparison concerning heavy vehicles. The cook appears on the list of occupations covered by the HK-dir system and in the case materials, but in the package of 28 October there was no updated assessment of this qualification.
The comparisons concern specific qualifications, periods and Norwegian equivalents. They are not individual decisions. A positive opinion about the motor vehicle mechanic, however, raises a specific question: what else prevents the resolution of the candidate’s case if the occupational comparison was in their favour? In the case of a negative assessment the question is: can the candidate demonstrate the missing element in a manner provided for by the regulations, and if not in this procedure, where should they turn?
There is also a question about the comparative material. The June letter from HK-dir describes the Polish state vocational examination in the 2019 formula, associated with the CKE and OKE system. The journeyman’s certificate issued by the chamber of craftsmen comes from a different examination procedure. The excerpt of the letter alone does not prove that the authority applied an inappropriate standard. However, it should clarify which Polish examination standards and documents it actually compared the Norwegian requirements with.
It is worth remembering here the appeal case 2026/0720. In September the commission overturned HK-dir's refusal and returned the matter of the Polish mechanic-fitter qualification for reconsideration. This is a separate case, not a decision regarding the D&A exams, and the commission itself did not grant recognition. However, it shows why an individual justification and the possibility of appeal matter. A person left without a decision still has not received a substantive ruling that they could respond to.
Norway needs skilled workers. Does it give them a reason to stay?
NAV estimated that in 2026 Norwegian employers were missing about 34,000 people. In the study report for the occupational group of construction and engineering works the shortage was estimated at 4,750 people. Meanwhile SSB reports that in 2025, 10,500 labour migrants from outside the Nordic countries arrived in Norway — the fewest since 2005. Poland was still the largest country of origin in that group, with 1,820 people. These are inflow figures that do not tell how many Poles left or why. There is no basis to causally link them to HK-dir's actions. They are, however, a reason to take seriously the question of what Norway is doing to retain people who already work here and want to develop.
The Norwegian language matters for safety, cooperation and life outside work. A person working shifts and supporting a family cannot always immediately enter a vocational training pathway in Norwegian. The possibility of taking the exam in Polish allows them to confirm what they already know. The next step should be clear: if it is necessary to fill gaps in Norwegian standards, professional terminology or specific skills, the candidate should be informed what, where and in what procedure they can make up those gaps. Not everyone will have the right to the same pathway; everyone should receive clear information that applies to their situation.
The Norwegian Equality and Anti-Discrimination Ombud, LDO, told us that it is not aware of the basis or the scale of the suspension and cannot assess whether discrimination occurred in this matter. It noted, however, that the lack of recognition of foreign education can hinder people from abroad from full participation in the labour market, even when it does not constitute discrimination in the legal sense. This is the core of the integration problem: a barrier can have a real effect even when no document reveals ill intent.
What do we expect from HK-dir and the ministry?
Timeframe and scope. Which applications are waiting, since when and according to what criterion? How many cases are suspended, how many ended in recognition, and how many in refusal? Can numbers be shown by occupation and by the pathway to obtaining the qualification?
Clarifications on what can start immediately. While waiting, can documents be verified, substantive comparisons completed and cases decided that the question to the ministry does not concern? What exactly remains to be determined in the case of light vehicle mechanics? What is the status of cooks?
Assessments of the effects of the suspension. Who and when will check how the delay affects promotion and pay? What solutions were considered besides leaving the entire affected group without a decision?
Cooperation that gives people a concrete path. Will HK-dir invite the chamber, D&A, representatives of employees and the industry, and Norwegian training institutions to a discussion about standards? Will it publish which proofs of practice and which examination standards it takes into account, and what alternative options candidates have?
A clear response from the ministry. When will the ministry release the interpretation regarding 26/3544? How will HK-dir implement it toward people who have already submitted complete applications?
You can set high requirements and help people meet them. Norway benefits when someone studies theory after work, documents experience, takes an exam and wants to tie their future to this country. The role of the agency is to determine how to reliably verify their competencies, and then tell them what comes next.
The sharpest question is therefore: does Norway want to retain professionals, or is it enough for it that they perform skilled work, even if for months they cannot learn on what terms their qualifications will be assessed? If the country wants these people to stay, the answer should be clear requirements, a deadline and a path to promotion. It is hard to expect someone to tie their future to a place where they are trusted on the job, but cannot be told what to do to have their qualifications recognized.
Material status: 11 November 2026. Polish translations of Norwegian statements are editorial translations.
Documents and responses from institutions
HK-dir: request for interpretation of 29 June 2026 (26/13834-1); letter to D&A about how the agency's visit is presented (26/13738-1); documents concerning the scale and course of the cases (26/21334-3); press response of 23 October (26/21412-3); response to the request for access to the files of 28 October together with professional comparisons (26/22242-2); interim response of 30 October (26/21412-7); authorization of quotes in case 26/21412.
Kunnskapsdepartementet: letter of 15 October (26/4899-2), press correspondence concerning case 26/3544 and provided industry correspondence (26/2050 and 26/4877).
Chamber of Crafts in Radom: response of 28 October 2026 (NS-189/26).
Arbeidstilsynet: response to the editorial office with a quote for attribution assigned to Tonje Faanes; current sector minima.
LDO: response to the editorial office with a quote for attribution assigned to Elida Steinsdatter Andersen.
