The short answer
Shorter clinical placements do not automatically justify compensatory measures. Authorities must assess whether lawful work and subsequent clinical training offset substantial differences. In B-2612/2024 of 20 April 2026, the Federal Administrative Court allowed the appeal, annulled the Swiss Red Cross (SRC) decision and remitted the matter. It did not grant recognition.
What happened?
The applicant qualified in Romanian kinetotherapy in 2022. The SRC imposed a six-month adaptation period or aptitude test in April 2024. Her initial clinical placements comprised 22 ECTS or 660 hours, compared with more than 1,400 hours in the Swiss reference programme. The court accepted that this represented a substantial difference.
Applicable law
This is professional recognition, not academic diploma equivalence. The Swiss Health Professions Act, the Switzerland–EU Free Movement Agreement and Annex III, and Directive 2005/36/EC as incorporated into Swiss law apply. Article 14 requires an individual, proportionate assessment of essential differences and relevant professional experience; later EU amendments are not automatically applicable in Switzerland.
Why the assessment was insufficient
The SRC excluded 31 of 180 ECTS, including sports and language courses. Sports instruction could be relevant and required a reasoned evaluation. The authority also needed to assess whether further clinical work and studies addressed the acknowledged placement-hour gap.
Professional experience and later training
The record showed 340 hours of lawful physiotherapy work in Romania and 810 hours of clinical placements in a later master's programme. The combined 1,150 hours exceeded the initial 740-hour shortfall, but hours alone are not decisive: competencies and activities must be evaluated. Supervised student placements do not automatically constitute independent professional experience.
Practical example
For example, a physiotherapist with post-qualification patient-care experience and a clinically focused master's should document dates, hours, responsibilities, authorisation to practise and acquired competencies. An employment certificate listing only the job title may be insufficient.
The judgment's actual outcome
The court allowed the appeal, annulled the SRC decision and ordered reconsideration with adequate reasons, potentially including further employer evidence. It did not recognise the diploma or exclude future compensatory measures. Cantonal professional licences are a separate question.
What applicants should prepare
Begin with the SRC PreCheck. Gather the diploma, transcript, detailed syllabuses, placement records, postgraduate training and employer confirmations of lawful work, duties and hours. Where a measure is imposed, request a precise explanation of remaining substantial differences and review the applicable appeal deadline.
Primary sources
Federal Administrative Court B-2612/2024 (20 April 2026, dispatched 23 April 2026); Swiss Health Professions Act; Directive 2005/36/EC; Swiss Red Cross recognition guidance.