A working document published by the General Secretariat of the Council on 25 June 2026 compiles written comments from EU member states on the Presidency compromise text for the proposed EU Talent Pool Regulation, following discussions in the Working Party on Integration, Migration and Expulsion (Admissions) on 2 May 2024. The comments reveal significant divergences among member states on the regulation's scope, administrative obligations, and safeguards against abuse.
Austria proposes amending Article 1(2)(d) to clarify that national or bilateral frameworks of member states, not third countries, apply for skills validation. Croatia raises concerns about Article 10's mandatory composition of National Contact Points, which would require two experts from employment and immigration, questioning the administrative burden and funding. Croatia also flags Article 11's risk of registering profiles of individuals with entry bans and Article 17's requirement for personalised information as potentially overly burdensome.
France seeks to exclude temporary work agencies and private employment agencies from the regulation's scope under Article 2, citing abuse risks. France supports Article 12's reformulation but wants clarification that profiles flag participation in activities under Talent Partnerships, not the partnerships themselves. France also requests that labour market tests precede vacancy posting under Article 15 and proposes collective rather than personalised information under Article 17.
Greece proposes adding "as allowed by national legislation" for other participating entities in Article 2, as national law does not permit private agencies to act as employers. Greece prefers "discussing" over "exchange practices" in Article 9 and seeks clarification on how profiles link to Talent Partnerships under Article 12.
Italy proposes aligning Recital 14 with Article 6(5) on automatic removal of unused profiles after two years. Italy suggests Recital 23a clarify that temporary work agencies fulfilling due diligence should not be suspended for employer violations, and proposes checking with employers before cancelling vacancies after one year under Article 13(4)(c).
The Netherlands welcomes changes to prevent improper use for immediate posting of third-country nationals but considers safeguards insufficient. The Netherlands proposes special attention in the report on whether the Talent Pool addresses labour shortages.
The comments focus on excluding private employment agencies, clarifying National Contact Point composition, ensuring information provision is not overly burdensome, and strengthening safeguards against abuse. Several member states propose amendments to limit the regulation's scope and administrative obligations, reflecting a tension between EU-level harmonisation and national sovereignty over labour migration. The next step is for the Council to consider these comments and revise the compromise text before further negotiations with the European Parliament.