The pathway for a nation’s specialty which is already present in Annex V, for OMFS that will be either dual degree Dental, Oral and Maxillofacial Surgery (DOMFS) or single medical degree Maxillofacial Surgery (MFS), is relatively straight forward. It is called the Article 21 notification procedure. This paper will focus on the dual degree DOMFS pathway, but the details are similar for MFS. This information can be downloaded as a PDF from this link.
1. Evidence of the dual degree requirement in law or regulation is required.
The DOMFS training pathway must be “hard-wired” in the national medical training rules/law. All those completing training and being awarded the title of Specialist in DOMFS must be required to complete a validated basic medical studies (Article 24) and basic dental studies (Article 34) before completing the programme. “Custom and practice” of dual degree training is not sufficient.
The evidence required listed in Annex V:
- the exact title of the evidence of formal qualifications (for point 5.1.3)
- the nature of the evidence e.g. certificate or listing
- the body that issues this evidence (for point 5.1.2) Chamber or Ministry
2. Duration of Specialty Training Programme must be at least 4 years
Within Annex V the minimum duration of training is four-years, including Article 25 conditions for the basic medical studies. Training must be in a recognised setting under supervision. The legal/regulation documentation about DOMFS training must show that the duration of training exceeds this. There is no scope for training to be shorter – this is a ‘hard gateway’ but Bologna principles apply in that there is the possibility of recognising training elements achieved prior to specialty training.
3. Evidence that the specialty is listed as a medical specialty on the list of regulated professionals in that nation in a manner that matches the EU Regulated Professions Database.
4. Submit the evidence above to the Commission Under Article 21a(3) of Directive 2005/36/EC through the Internal Market Information System (IMI).
This notification is the act that actually starts the listing process.
5. Commission assessment and Group of Coordinators consultation.
The Commission checks the notified provisions against Title III, Chapter III, and consults the Group of Coordinators for the recognition of professional qualifications(an expert group within the Commission). This is the stage when other member states can raise objection and is when a DOMFS notification is most likely to be queried.
6. Delegated act amending Annex V (performed by the Commission).
If satisfied, the Commission inserts an amendment into points 5.1.3 and 5.1.2 by delegated act under Article 21a(4)/Article 57c. These are bundled into the periodic consolidated Delegated Decision — updated on a roughly annual cycle. Delegated Acts/Decisions are subject to the Parliament's and Council's right of objection before entering into force.
7. Publication in the Official Journal and update Annex V.
On publication the listing takes effect, and DOMFS holders from that nation gain automatic recognition across the EU under Article 21.
Advice from AI and other sources for those wishing their DOMFS or MFS to be in Annex V
Engage the national EU coordinator early and timing the IMI notification to catch the annual consolidation cycle avoids losing a year waiting for the next Delegated Decision.
When the second qualification is obtained as part of the training programme.
There is regulatory divergence in EU nations over whether the second (dental) degree may be acquired during specialist training or must be completed and validated beforehand. For example the UK regulator used to interpret the footnote as meaning both qualifications must be obtained before entering specialty training.
Fortunately, the Commission will accept a clear unambiguous statement that both primary degrees and basic training must be "completed and validated" before specialty training is completed.
Evidence of Appropriate Curriculum Content
Mapping the nations OMFS curriculum to the UEMS OMFS European Training Requirement will reassure the Commission that the training "meets the harmonised standard."
Having this documented in advance avoids delays and questions.
Listing Details of DOMFS Training on the OMFS Section of UEMS Website
Ensure that the informal evidence base that the coordinators draw on is consistent with the submitted documents.