The Emerging ASEAN Approach to Mutual Recognition: A Comparison with Europe, Trans-Tasman, and North America

Discussion Papers


by Shintaro Hamanaka and Sufian Jusoh

September 2016


Existing studies on mutual recognition agreements (MRAs) are mostly based on the European experience. In this paper, we will examine the ongoing attempts to establish a mutual recognition architecture in the Association of Southeast Asian Nations (ASEAN) and seek to explain the region’s unique approach to MRAs, which can be classified as a “hub and spoke” model of mutual recognition. On one hand, ASEAN is attempting to establish a quasi-supranational ASEAN-level mechanism to confer “ASEAN qualification” effective in the entire ASEAN region. On the other hand, ASEAN MRAs respect members’ national sovereignty, and it is national authorities, not ASEAN institutions, who have the ultimate power to approve or disapprove the supply of services by ASEAN qualification holders. Such a mixed approach to mutual recognition can be best understood as a centralized mechanism for learning-by-doing, rather than centralized recognition per se.

Keywords: Mutual recognition agreement (MRA), professional qualifications, trade in services, hub and spoke, supranational mechanism, ASEAN, regionalism
JEL classification: F15, F53, F55

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