*Update 28.10.2025 here’s the response to our note, which makes no mention of the  issue of staff being denied the opportunity to attend an in-person exam.*

*Update 18.09.2025: we’ve added a language-level-equivalence table below, many thanks to the reader who provided this. *

Original article: Here’s one more issue raised by staff:  Generation 2004 was contacted by colleagues across different staff categories, including Contract Agents 3b,  who were refused permission to attend in-person final exams for the in-house 12-level language courses. One reason given was that at this stage they are not required to validate their third language under the staff regulations or Conditions of Employment of Other Servants (CEOS).

While we understand the need to prioritise colleagues who must validate their third language in order to be eligible for promotion[*] or contract renewal, it is unfair to exclude others who have successfully completed an official internal course at the required level, whatever the exam format applied. Will those excluded colleagues be allowed to progress to the next level of the language course without having sat the exam? Will they be permitted to sit an equivalent exam externally in work time and with a contribution to the cost?[**]

Current DG HR policy and its consequences 

Indeed, the administration has decided that all final written exams under Article 45.2 of the Staff Regulations (page 41) and Article 85.3 of CEOS (page 214) at level 6 (equivalent to CEFL B2) or above must be taken in person. Despite courses being held online, exams must take place under invigilation (no remote proctoring).  

At the same time, online exams to officially validate the required level for promotion or contract renewal are no longer accepted, although they were in the past. Generation 2004 perceives this inconsistent approach as discriminatory. Internal competition exams and their EPSO counterparts, for instance, are conducted online and fully recognised, raising the question of why a more restrictive standard is now applied to language exams only. 

Unequal treatment and missed opportunities 

Even more concerning is that some colleagues have been refused access to exams altogether because they are not yet formally concerned by the third-language rule.

“Officials shall be required to demonstrate before their first promotion after recruitment the ability to work in a third language among those referred to in Article 55(1) of the Treaty on European Union.” Article 45(2), Staff Regulations

“Contract staff in function group IV shall before renewal of a contract for an indefinite period be required to demonstrate the ability to work in a third language among those referred to in Article 55(1) of the Treaty on European Union.”Article 85(3) CEOS

This particularly affects contract agents (CA 3b) since, while they can be evaluated/appraised, they cannot be promoted/reclassified, hence the reason that they may not immediately need that third-language  validation. Generation 2004 believes in long-term thinking and investing in the professional future of staff within the European institutions. If those colleagues were to become CA3A (FG IV) or officials, that third-language validation would indeed become necessary.

While discussing promotion proposals, Generation 2004 regularly encounters the cases of colleagues whose careers are blocked because of the missing third-language accreditation, regardless of how well they might speak a third language. Preparing for language exams requires major personal effort, often alongside demanding workloads. Denying recognition of online exams risks undermining these efforts and preventing colleagues from progressing in their careers, ultimately affecting staff morale and staff retention.

Our position 

Generation 2004 considers the administration’s stance unnecessarily rigid and outdated, especially given the broad acceptance of online learning and assessment across the EU institutions and beyond. We call on the administration to accept online final exams (level 6/B2 and above) as valid for third-language recognition Alternatively, Generation 2004 asks that they raise awareness and better fund the own-initiative-training options for sitting language exams externally.

We have contacted DG HR on this matter and are awaiting their intervention. Generation 2004 will continue to advocate for fairer, more flexible procedures that reflect modern learning practices and ensure equal opportunities for all colleagues. 

As always, if you have questions or comments, feel free to contact us. 

References 

EU Learn platform for the registration for language courses 

EC Language courses 

Third Language final exam 

[*] Check whether you can be promoted/reclassified and how soon you might need to have a third language accredited. Note that Local agents are promoted via different processes:  here are the rules for delegations (EEAS) and here is an example  for those in EU Representations.

[**] Check the Indicative list – language diplomas & certificates to see options to validate a B2 (or higher) in a third EU language externally (e.g. Luxembourg has one exam centre, and several language authorities offer exams in many different countries: Instituto Cervantes or the Goethe Institut). This type of exam is recognised outside the Commission and can often be done without any classes attached. A Generation 2004 colleague validated a third language in this way, doing the exam only, in work time and with a contribution paid (but this was 10 years ago).

Under own-initiative training, you can request both the time to do those exams (and even a contribution to the cost of the exam itself), though you may be only partially successful. Nevertheless, this additional use of resources to circumvent an unwritten rule excluding staff from an exam which has no additional cost may be noted higher up. In the meantime we wait for a response to our note.