Can a Polish Electrician Legally Work on Your German House? How EU Recognition Really Works

A Polish electrician wants to rewire your house in Germany. A Portuguese team is quoting for a roof in France. A Lithuanian firm is the cheapest bid for your renovation in Sweden. Are any of them allowed to do the work, and if something goes wrong, who is actually liable? The answer sits in a body of EU law that almost no homeowner has heard of, and it is genuinely useful once you know how it works, because it tells you exactly which document to ask for.

Two different legal routes, and they are not interchangeable

A tradesperson from one member state can work in another under one of two mechanisms, and the distinction determines what you should be checking.

The first is establishment. The professional moves to the country, sets up a business there, and becomes subject to the same registration and licensing as a domestic firm. A Polish electrician who establishes in Germany registers a German business, appears in the German commercial register, and must satisfy the German requirements for the regulated craft, including the Meister requirement where it applies. From your side as a customer, an established firm is a domestic firm and you check it exactly as you would any other.

The second is temporary provision of services. The professional remains based in their home country and comes over for a specific job. This is where the special rules bite, and where most homeowner confusion lives.

How recognition works for a temporary job

The Professional Qualifications Directive lets a qualified professional from one member state provide services temporarily in another without full re-registration. For professions with health or safety implications, and electrical and gas work qualify comfortably, the host country can require a prior written declaration before the work starts, usually renewable annually, and can require verification of the professional's qualifications the first time.

What this means practically is that a legitimate cross-border tradesperson working temporarily on your home should be able to show you the declaration or acknowledgement from the host country's authority. It is a real document produced by a real process. A firm that has never heard of it, working temporarily in a regulated trade, has not gone through the process.

The European Professional Card, and why you probably will not see one

The EU created a European Professional Card, an electronic certificate confirming that qualifications have been recognised in another member state. It is genuinely useful, and it currently covers only five professions: nurses, pharmacists, physiotherapists, mountain guides, and real estate agents.

That last one matters for property buyers. If you are dealing with an estate agent operating across borders inside the EU, the EPC is a real and checkable credential. For electricians, plumbers, and builders it does not exist, and anyone waving something they call a European trade licence at you is showing you a private certificate rather than a public one.

Posted workers: the rule that protects you as well as them

When a company in one member state sends its employees to work temporarily in another, the Posted Workers Directive applies. The posted workers must receive the host country's rules on pay, working hours, health and safety, and holiday. The posting has to be declared to the host country's authorities before the work begins, through national systems such as SIPSI in France, the Zentrale Auslands- und Fachvermittlung notification in Germany, or Limosa in Belgium.

Homeowners tend to read this as an employment matter that does not concern them. It concerns them for two reasons. First, in several countries the client can be drawn into liability for unpaid wages or social contributions in a subcontracting chain, and construction is the sector where those rules are strictest. Second, an undeclared posting is a strong signal about how the rest of the operation is run. A firm cutting corners on a mandatory declaration is unlikely to be scrupulous about your building regulations.

What genuinely does not travel

Recognition of qualifications does not carry the practical authorisations across the border, and this is the gap that causes real problems on site.

• Connection rights to the local grid or gas network usually require registration with the local network operator or a national scheme, held by a firm authorised in that country.
• Certificates of conformity that must be issued at the end of the work, such as Italy’s DM 37/08 declaration, generally have to come from an installer authorised under that national system.
• Mandatory decennial insurance in France, Spain, Italy, and Belgium must respond in that jurisdiction; a home-country liability policy frequently will not.
• Building-control sign-off and permit responsibility remain local, whatever the contractor’s nationality.

The consequence is concrete. A foreign firm may be perfectly entitled to carry out the labour and still be unable to issue the certificate you need to sell the house, insure it, or reconnect the supply. Ask who will sign the completion documentation before you accept the quote, not after the work is done.

The questions that settle it in five minutes

• Are you established here with a local company registration, or working temporarily from your home country?
• If temporary, can you show the prior declaration for this regulated activity?
• If you are posting employees, has the posting been declared, and to which authority?
• Who will issue the certificate of conformity or completion, and are they authorised in this country?
• Which insurance policy covers this work in this jurisdiction, and can I see the certificate with its dates?
• Are you registered with the local network operator for the connection, where the job needs one?

Why the cheap cross-border quote is often genuinely cheaper

It is worth saying plainly that a lower bid from a firm in another member state is not inherently suspect. Wage levels differ enormously across the EU, and a well-run Polish or Portuguese firm with proper qualifications, a filed declaration, and appropriate insurance can legitimately undercut a domestic competitor while doing excellent work. The single market is supposed to produce exactly this outcome.

The problem is not the origin of the firm, it is that the same price gap attracts operators who achieve it by skipping the declaration, the insurance, and the certification rather than by having a lower cost base. The checks above separate the two, and they take one conversation.

Cross-border hiring inside Europe is a real advantage available to homeowners, and most never use it because the legal position feels opaque. It is not especially opaque once you know there are exactly two routes, that the paperwork for the temporary route is a declaration you can ask to see, and that certification and insurance are the things that stubbornly stay local. Ask those questions, and a foreign quote becomes just another quote you can judge on merit.