European Sociological Review, Vol. 16 No.

1, 9^26 9

The Professionalization of Everyone?

A Comparative Study of the Development of the Professions
in the United Kingdom and Germany
Mark Neal and John Morgan

The concept of `professionalization' is commonly used to describe how occupations become

recognized as `professions', and how they go about consolidating this status and improving their
services. Contemporary debate often glosses over the historical development of the professions.
Indeed, professionalism is often discussed and debated in a way that treats professionalization as a
recent and uniform phenomenon. Taking a comparative historical perspective this paper identi¢es
the stages through which occupations in the UK and Germany developed into the recognized pro-
fessions of today. In doing so, it demonstrates that the process of professionalization has been
radically di¡erent in the two countries, in particular with regard to the role of the state in initiating
and administering professional bodies. Overall the study demonstrates that the process of pro-
fessionalization in the UK has been `bottom up', in that professional bodies have resulted from
spontaneous activities at the occupational level to secure professional status. By contrast, profession-
alization in Germany has been `top down' in that the state has played an active interventionist role in
the initiation and administration of the professions. In detailing these di¡erent patterns this paper
aims to provide an empirical resource for researchers in the ¢eld, and to contribute to the understand-
ing of the di¡erences in the organization and administration of professional services in the UK and
in Germany. Finally, the emerging role of the EU in the administration, training, and licensing of
professionals is discussed. The point is made that while particular EU directives have changed the
relationship between the professions and the state in both countries, large-scale intervention by the
EU has resulted in a new form of Euro-professionalization, typi¢ed by the establishment of the new
profession of `eco-auditors'.

This article discusses the ¢ndings of a comparative
research project into the development of the pro-
fessions in the United Kingdom and in Germany.
In contrast to traditional ethnocentric assump-
tions about the universal applicability of the
Anglo-American experiences of professionalism,
the study uncovered markedly di¡erent forms of
professionalization in Germany and the United
Kingdom, particularly in terms of the role of the
state in initiating, sanctioning, and administering
new and established professions. The ¢ndings
thus agree with established research in that the
& Oxford University Press 2000
development of the professions in the United
Kingdom has been `spontaneous', in the sense
that professionalization has largely been the result
of voluntary association (Macdonald, 1993: 72^79);
while in Germany there has been `reform from
above' (Siegrist, 1990: 46) in that the state has
played ^ and continues to play ^ an active role in
their establishment, structuring, administration,
and in training (Rueschemeyer, 1983; Macdonald,
1993: 89^94).
Building upon the multi-stage temporal analyses
of the evolution of the American professions
10 MARK NEAL AND JOHN MORGAN
produced by early writers such as Caplow (1954) and
Wilensky (1964), this article outlines the key stages
in the development of the professions in England
and Germany, and shows how an analysis of these
can contribute to the debate about the contemporary
development of the professions, particularly in the
context of the European Union. It is argued that
while European Union institutions play an increas-
ingly important role in the development of the
professions, they e¡ectively favour the German
approach. They do this in two ways. First, through
transparency regulations such as Directive 89/48/
EEC such institutions undermine the autonomy of
national professional bodies, while increasing their
own power to determine the structure, administra-
tion, accountability, and training within these
professions. Second, they have recently adopted an
extreme version of `professionalization from above'
by deciding to establish the existence of a completely
new, and quite controversial profession ^ that of
the eco-auditor.
The Natural History of the Professions:
A Neglected Debate
Much of the sociological discussion of the profes-
sions is to be found in four interrelated debates: the
de¢nitional controversy; the debate about the pro-
cess and implications of market closure and social
closure; the ethnographies of professional work;
and the histories of particular professions.
The problems associated with de¢ning
`professions' and `professionalization' have con-
cerned sociologists for generations. Whereas early
Anglo-American writers bullishly identi¢ed
professional `traits', common features that distin-
guished professions from mere occupations,
evidence has built up that undermines the universal
applicability of Anglo-American models (Malatesta,
1995; Rueschemeyer, 1983; Jarausch, 1990a, 1990b).
Indeed, it is now widely accepted that the terms
`professionalization'and `profession' have meanings
in Anglo-American societies that are not directly
translatable or applicable in other languages
(Jarausch, 1990a, 1990b). The implications of this
are important: some see a need to suspend the con-
cept of `profession' and replace it with the less
problematic term `occupation'; others see the de¢ni-
tional problem as a complicating factor, but one in a
more complex world than was previously thought
(see Freidson, 1994: 1^29).
A second strand of the research has been highly
critical of the established professions, particularly
of the process of social closure and the consequent
exploitation of the monopoly supply of particular
knowledge-based skills and services. Researchers in
this ¢eld have commonly characterized the striving
of occupations for professional status as an attempt
to cut out competing interest groups, and thus
maximize their economic power and political in£u-
ence (Johnson, 1981; Abbott, 1988). Such critics see
`professionalization'not as a process of guaranteeing
and improving services (a characterization com-
monly marketed by industry and widely accepted
by the public) but as a process which ensures
public dependency and exploitation (Larson, 1977;
Freidson, 1973). This approach was more in£uential
in the 1970s and 1980s; but the main critique, that
occupations professionalize primarily to exclude
competing interest groups and produce a mono-
polistic market for their services, remains relevant
(Murphy, 1988).
From the 1970s onwards there have also been a
number of interesting ethnographies of various pro-
fessions that concentrate upon the way professionals
such as medics, accountants, and lawyers act to
maintain their professional status, and the way
their training is organized, taught, and understood
(Dingwall, 1976). What such studies have in com-
mon is that they describe the ways in which the
members of professional groups sustain profes-
sional status at the level of social interaction
(Harper, 1986). One aspect of these activities that is
common to many ethnographies, and that sheds
light on the previous approaches concerning de¢ni-
tion and market closure, is the way that the members
of professional groups routinely disparage members
of related or competing groups. Professional
boundaries are thus sustained at the level of everyday
life, and members' ideas about their identity are
reinforced. The ethnographic approach to the
professions thus demonstrates that the issues of de¢-
nition and of social closure are not mere academic
constructs, but are everyday concerns for profes-
sionals as part of their work. Doctors sustain the
public perception of their profession through the
 COMPARISON OF THE DEVELOPMENT OF THE PROFESSIONS: UK AND GERMANY
routinized use of subtle cues and interactive
practices during patient contact. Whereas such
practices are `embedded' in their everyday work,
de¢nitional concerns are directly oriented to in
such cases as medical malpractice. Likewise, doctors
are concerned both with de¢nitional and social-
closure issues when, as part of their everyday dis-
course, they discuss frauds, quacks, and those
involved in alternative medicine (Sinclair, 1997).
Sociology, as opposed to economics, psychology,
or law, has thus made a distinctive contribution to
the modern understanding of the professions: why
occupations strive so strongly for `professional' sta-
tus (though this may di¡er in di¡erent countries);
how the established professional institutions instil
professional conduct among their members
through regulations and training; and how the insti-
tutions and their public pro¢les are sustained by
members' activities and discourse in the everyday
pursuit of their work.
The Temporal Aspect
Such approaches as these help us to answer parti-
cular kinds of questions. How can we distinguish
between professions and mere occupations? Why
do occupations strive for professional recognition?
How do professionals sustain their professional sta-
tus? Such questions are interesting and important,
and the outlined approaches tackle them well.
However, if we ask di¡erent kinds of questions,
such approaches are less suitable. Certainly, if we
ask why the professions in di¡erent countries are
structured in the way that they are, and have the
status and in£uence they do, these approaches are
less illuminating, the reason being that in order to
answer such questions we require a more compara-
tive and historical approach to the development of
the professions.
Some writers in the early sociology of the profes-
sions did actually address the historical development
of the professions, albeit in a limited way and with
limited impact upon the subsequent debate. One of
the ¢rst contributions to concern itself with the
history ^ or the `evolution' ^ of the professions
was Carr-Saunders and Wilson's (1933) The Professions,
which documented the history of 22 professions in
11
the United Kingdom, and drew general conclusions
about the stages through which occupations had to
pass through to achieve professional status. They
thus laid the foundations for an approach that
sought patterns in the histories of the various pro-
fessions in order to explain the present division of
services into professional and non-professional
occupations. In this way, Carr-Saunders and Wilson
developed a socio-historical approach which had
the potential to contribute to the understanding
of occupational structure of modern industrial
societies. Unfortunately perhaps, this approach was
subsequently neglected in favour of the other three
approaches.
Caplow (1954) resurrected this socio-historical
approach about the routes particular occupations
had taken to achieve professional status, and sug-
gested the following temporal sequence in the
evolution or development of professional associa-
tions (139^140):
1. the establishment of a professional association;
2. a change in the name of the occupation;
3. the development of a code of ethics;
4. prolonged agitation to obtain the support of
public power;
5. the concurrent development of training
facilities.
This `evolutionary' approach to the analysis of the
professions was adopted and developed further by
Everett Hughes, who produced a theory of `the
natural history of professionalism' (Hughes, 1958),
which again identi¢ed certain common stages
through which occupations had to pass in order to
achieve professional status.
The most important empirical contributions on
the subject, however, were made by Harold
Wilensky. Initially concerned with the professiona-
lization of social welfare (Wilensky and Lebeaux,
1958) and hospital administration (Wilensky, 1962),
Wilensky expanded his research to address the
evolution of professions generally. The results of
this wider study were written up in an article, `The
Professionalization of Everybody?' (1964), which
considered the history of eighteen occupations in
the USA, and uncovered what he considered to be
the typical process or `rites of passage' through
which the `established' professions developed.
Wilensky thus examined the history of the eighteen
occupations and applied the sequence that emerged
12 MARK NEAL AND JOHN MORGAN
from the development of the `established' pro-
fessions in the United States to all these other
occupations. Wilensky argued that this analysis
con¢rmed that there was a `typical' sequence of
events, and the data supported his case. Indeed,
only 32 of 126 (25.4 per cent) dates for crucial events
varied from the usual order, and the variation for the
`established' professions was only 21 per cent, rising
to 29 per cent for what he described as`doubtful pro-
fessions'such as advertising and funeral direction.
Wilensky considered the typical sequence to be as
follows (142^146):
1. The occupation became full time. Originally
most professions were not practised full-time
but were carried out on a piece-meal basis.
2. Once the occupation was full-time, the question
of training soon arose.The early recruits, the cli-
ent public, or a professional association pressed
for the founding of a training school. If these
training schools did not begin within uni-
versities, the budding professionals eventually
sought contact with universities and there was a
steady development of study courses, academic
degrees, and research programmes to expand
the knowledge base. A corps of people who
taught rather than practised was an inevitable
accompaniment.Where professionalization had
gone further, the occupational association did
not typically set up the training school but the
schools usually promoted an e¡ective profes-
sional association.
3. Those pushing for prescribed training and the
¢rst to complete it combined to form a profes-
sional association.
4. There was persistent political agitation for pro-
tection by law for the occupation in question.
Where the area of competence was not clearly
exclusive, legal protection of the title would be
the aim (e.g. the registered engineer in the
USA). Where de¢nition of the area of com-
petence was clearer, then the mere performance
of the act by a non-quali¢ed person would be
declared a crime (e.g. medical practice law as in
the USA).
5. Eventually rules to eliminate the unquali¢ed
and the unscrupulous, rules to reduce internal
competition, and rules to protect clients and to
emphasize the service ideal were embodied in a
formal code of ethics.
Wilensky's model was initially well received and
in£uential. Unlike other enquiries into professional-
ization it was the product of empirical research, and
the results were published before the rise of the
critical approach. So in£uential wasWilenky's article
that his multi-stage temporal model came to be used
outside the social sciences by members of those
occupations that aspired to professional status.
Indeed, the authors have heard of several occasions
where speakers who were advising occupational
representatives upon `how to achieve professional
status' produced Wilensky's model. Tellingly, the
model was used not as a historical analysis of the
professions, but as a game-plan for `how to achieve
professional status'.
Since Wilensky's article was published, little sub-
stantial historical work on evolutionary models has
been produced. Among those who pursued this line
at all, Harries-Jenkins (1970) e¡ectively proposed a
three-stage model for the United Kingdom: the
introduction of apprenticeship (learning by doing);
the introduction of professional examinations to
supplement the apprenticeship; and the intro-
duction of graduate entry. Likewise, Larson (1977)
drew attention to the historic matrix of modern pro-
fessions and saw the development of the professions
as having gone through distinct phases linked to the
dominant mode of production at the time, identi-
¢ed as being feudal, capitalist, and monopoly-
capitalist. However, Larson made no attempt to con-
struct any more formalized models of the evolution
of the professions to re£ect these di¡erent phases.
Concerning the professions in Germany,
Fleischmann (1970) examined how high-status
professions in Germany had increased their status
through ¢ve stages of state intervention:
1. statutory regulations concerning the training for
certain occupations;
2. statutory regulations concerning both training
and licences to practise;
3. statutory regulations concerning training,
licences to practise, and a code of practice;
4. statutory regulations as in (3), but with a camera-
list system under public law involving mandatory
membership of a professional chamber.
5. statutory regulations as in (4), but also incor-
porating statutory rules of conduct.
Like Wilensky, Fleischmann assumed that the pro-
fessions always had and always would evolve in the
 COMPARISON OF THE DEVELOPMENT OF THE PROFESSIONS: UK AND GERMANY
same way. Unlike Wilensky, however, he did not
develop a comprehensive model of professional
development.
The Comparative Historical Approach to
the Professions
Recent years have seen a rise in interest in the
development of the professions in di¡erent coun-
tries (e.g. Gispen, 1989; Malatesta, 1995). Largely
through the in-depth historical analysis of indivi-
dual professions, such studies have identi¢ed the
di¡erent routes key occupations have taken to
achieve professional status and authority within
di¡erent countries, and these studies have identi¢ed
the di¡erent systems and institutions that now pre-
vail as a result of these processes.
The remainder of this paper builds upon this
historical research by comparing the development
of the professions in the United Kingdom and
Germany. There is much to be gained from such a
comparative historical approach, not least of which
is an enhanced understanding of why di¡erent
advanced industrial societies currently have di¡er-
ent patterns of professional and non-professional
occupations, and di¡erent systems of professional
power, authority, and status. Through showing
how the professions are rooted in their countries'
respective histories and resultant institutional
frameworks, this approach sheds light on the pre-
sent cultural, institutional, and regulatory
constraints upon professions and other occupations
which are attempting to maintain or expand their
interests while dealing with the pressures of global-
ization within the context of the Single European
Market.
The Research
The research began as a comparative history of the
valuation professions in the United Kingdom and
Germany (Morgan, 1998).This comparison of a sin-
gle occupation was appropriate and useful, and
important di¡erences between the two professions
were discovered (see Tables 1 and 2). However,
although the ¢ndings about valuers agreed with
13
much of the existing British and German literature,
it was as yet uncertain just how typical the routes
valuers had taken to professional status within
these countries really were.
The decision was therefore taken to examine
and compare the historical development of a wider
spectrum of the professions in the United Kingdom
and Germany. This was done in order to assess the
existing literature on the topic, and in order to
analyse the development of the valuation profes-
sions in these countries.
In so doing, the question arose as to which
occupations should be included in the study, and
which should not. Previously, Freidson (1983) had
suggested that since it was not possible to de¢ne
`profession' satisfactorily, researchers should clearly
state what they meant when using the term and
should illustrate this with examples. After much
deliberation, this strategy was adopted. For the
sake of consistency and the purposes of comparison,
Wilensky's original de¢nition was used, and the
study was therefore restricted to `those knowledge-
based occupations which were normally organized
in the form of private practice in the United
Kingdom at the beginning of the twentieth cen-
tury'. As recommended by Freidson, this de¢nition
was also elaborated by examples of what were con-
sidered to be professions (seeTables 1 and 2).
Of course, this could lay the study open to de¢ni-
tional objections. However, because certain criteria
were required in order to decide whether to include
or exclude particular occupations, de¢nitional pro-
blems were bound to arise wherever the boundaries
between profession and non-profession were estab-
lished. We have however been explicit in our
de¢nition, and this at least ensures the comparison
of like with like, and the ability to compare the
development of these occupations in the UK,
Germany, and the USA.
In all, nineteen such occupations in the UK
were examined, as well as their counterparts, so
far as they existed, in Germany. The occupations
chosen in the UK were those of solicitor, chartered
accountant, veterinary surgeon, surgeon, dispen-
sing pharmacist, chartered patent agent, chartered
surveyor, chartered physiotherapist, chartered psy-
chologist, dentist, barrister, chartered structural
engineer, chartered naval architect, chartered actu-
ary, chartered town planner, optometrist, general
 14
Table 1. The process of professionalization in the United Kingdom

No. of deviations Compliance (%)

........................ ........................

Profession Full-time Articles Nat. assoc. Exams Charter Academic CPD Educatn. Self-reg. Total excl. CPD Total Excl. CPD
....................................................................................................................................................................................................

1. Chartered 19th c. Yes 1870 1872 1880 1902 1978 Yes Yes 0 0 100 100
accountant
2. Chartered 18th c. Yes 1868 1881 1881 1904 1981 Yes Yes 0 0 100 100
surveyor
3. Veterinary Early 19th c. Yes 1844 1844 1844 1903 None Yes Yes 1 0 89 100
surgeon
4. Chartered Early 19th c. Yes 1882 1889 1891 1985 None Yes Yes 1 0 89 100
patent agent
5. Solicitor Middle ages Yes 1825 1846 1831 1877 1985 Yes Yes 0.5 0.5 94 94
6. Surgeon Middle ages Yes 1800 1800 1800 1884 None Yes Largely 1.5 0.5 83 94
7. Dispensing Late 18th c. Yes 1841 1848 1843 1926 None Yes Largely 1.5 0.5 83 94
pharmacist

MARK NEAL AND JOHN MORGAN

8. Chartered Late 19th c. No 1894 1895 1920 1976 None Yes Yes 2 1 78 88
physiotherapist
a a
9. Dentist Early 19th c. Yes 1856 1858 None 1901 Non Yes Yes 2 1 78 88
10. Barrister 13th/14th c. Yes 13th/14th c. 1872 None 1872 1996 Yes Yes 1 1 89 88
11. Chartered Early 19th c. No 1908 1920 1934 1969 1996 Yes Yes 1 1 89 88
structural
engineer
12. Chartered Early 19th c. No 1848 1850 1848 1972 1986 Yes Yes 2 1 89 88
actuary
13. Chartered Mid-19th c. Yes 1860 1947 1910 1970 None Yes Yes 2 1 78 88
naval architect
14. Optometrist Mid-19th c. Yes 1895 1896 1995 1967 None Yes Partly 2.5 1.5 72 81
15. Chartered Early 20th c. No 1914 1920 1976 1932 1992 Yes Yes 2 2 78 75
town planner
16. General Middle ages Yes 1832 1858 1972 Middle 1989 Partly Partly 1 2 78 75
practitioner ages
17. Chartered Late 19th c. No 1901 1950s 1965 1901 None Yes Yes 3 2 67 75
psychologist
18. Chartered 19th c. No 1897 1899 1912 None 1995 Yes Largely 2 2.5 78 69
insurance
practitioner
19. Chartered 17th c. Yes 1834 1882 1837 1902 1993 Partly No 2.5 2.5 72 69
architect
Averages 1.5 1.1 83.4 87.1
a
Until 1956.
The explanations of the column-heading abbreviations are as follows: `Full-time': date became a full-time occupation; `Articles': date articles system originally used; `Nat assoc.': date national professional association
formed; `Exams': date professional exams became mandatory; `Charter': date Royal Charter granted; `Academic': date academic route introduced; `CPD': date CPD became mandatory; `Educatn.': date professional
association became responsible for education; `Self-reg.': date the profession became self-regulating.
Table 2.

No. of Compliance
Profession Full-time License Degree Prof. assoc. Chambers Educatn.? Stage-reg.? deviations (%)

COMPARISON OF THE DEVELOPMENT OF THE PROFESSIONS: UK AND GERMANY

...................................................................................................................................................................................................

1. Lawyer Middle ages Middle ages Middle ages 1871 1875 Yes Yes 0 100
2. General practitioner Middle ages Middle ages Middle ages 1872 1935/1955 Yes Yes 0 100
3. Surgeon Middle ages Middle ages 1726 1872 1970 Yes Yes 0 100
4. Architect Mid-19th c. 1831 1879 1903 1933/1969 Yes Yes 0 100
5. Veterinary surgeon Late 18th c. 1811 1830 1841 1936/1965 Yes Yes 0 100
6. Dispensing pharmacist Middle ages Middle ages 1808 1872 1933/1960 Yes Yes 1 86
7. Land surveyor Early 18th c. 1704 1803 1871 1938a Yes Yes 1 86
8. Auditor Late 19th c. 1863/1900 1900b 1896 1943/1961 Yes Yes 0.5 86
9. Dentist Early 19th c. 1825 1889 1859 1933/1952 Yes Yes 1 86
10. Patent lawyer Late 19th c. None 1933 1880 1933/1952 Yes Yes 1 86
11. Building engineer 19th c. 1831 1879 1871 1965/1987 Yes Yes 1 86
12. Tax adviser 1920s 1937 1961b 1922 1961 Partly Yes 1.5 79
13. Controlling engineer 19th c. 1926 1879 1976 None Yes Yes 2 71
14. Psychologist Late 19th c. None 1941 1946 None Yes No 3 57
15. Optometrist 19th c. None 1982 1905/1951 None Yes Yes 3 57
16. Sworn valuer 19th c. Mid-19th c. None 1961 None Yes No 3 57
17. Actuary Early 20th c. None 1942 1984 None Yes No 3 57
18. Physiotherapist Late 19th c. None None 1948 None Yes Yes 3 57
19. Insurance broker 18th c. None None 1918 None No No 5 28
Averages 1.5 77.8
a
Now abolished.
b
Non-graduate entry is also possible.
The explanations of the column-heading abbreviations are as follows: `Full-time': date became a full-time occupation; `License': date local licensing introduced; `Degree': date academic degrees introduced; `Prof.
assoc.': date national professional association formed;`Chambers': date national system of chambers instituted;`Educatn.?': is the state responsible for education/admittance;`Stage-reg.?': is the profession largely state
regulated?

15
16 MARK NEAL AND JOHN MORGAN
practitioner, chartered architect, and chartered
insurance practitioner.
Although thirteen of these professions had
counterparts in Germany that were almost identical,
there were no exact equivalents in Germany for
six of them: namely, chartered surveyor, barrister,
chartered structural engineer, chartered naval
architect, chartered town planner, and chartered
insurance practitioner.
. The profession of chartered surveyor in the UK
covers a number of disciplines that are regarded
as separate professions or occupations in many
other countries, e.g. land surveyor, quantity sur-
veyor, building surveyor, valuer, estate agent,
etc. The equivalent to the chartered surveyor in
Germany in the area of property valuation work
is the sworn valuer. Land surveying is also an
area of work carried out by some chartered sur-
veyors in the UK but is organized in Germany as
a completely separate profession.
. The German Rechtsanwalt carries out the work of
both the solicitor and the barrister and there is
no equivalent in Germany to the barrister alone.
. The work of the chartered structural engineer is
carried out in Germany partly by the building
engineer and partly by the controlling engineer.
Both of these professions were, therefore,
examined.
. There is no equivalent to the chartered naval
architect in Germany, this area of work being
carried out by engineers who are not organized
as a separate profession.
. The work of the chartered town planner in
Germany is often carried out by the architect
and there is no clearly homogeneous profession
of town planner as there is in the UK.
. There is no equivalent to the chartered insurance
practitioner in Germany but, as part of the work
of the chartered insurance practitioner involved
insurance brokerage, the occupation of insurance
broker was examined in Germany for comparative
purposes.
These considerations meant that a total of nine-
teen professions were also examined in Germany:
namely, lawyer, auditor, veterinary surgeon, sur-
geon, dispensing pharmacist, patent lawyer, land
surveyor, physiotherapist, psychologist, dentist,
building engineer, controlling engineer, actuary,
optometrist, general practitioner, architect, and
insurance agent.
The study thus involved comparative historical
research into the development of the professions
and professional practice in these two countries.
The research involved reviewing the existing litera-
ture on the development of the various professions
in both countries, and studying archival materials
such as letters, charters, training documents, and
in-house publications in libraries and within the
relevant professional bodies in both countries. By
way of checking the dates and procedures outlined
in the literature and archival sources, the research
also involved a simple postal survey of senior pro-
fessional administrators, followed by informal
interviews. Initially, such interviews were used for
clari¢cation about dates, de¢nitions, and develop-
ments that could not be obtained elsewhere. Soon,
however, they became interesting in and of
themselves, and developed into an increasingly
important source of data and insight.
As the research progressed, it was found that the
development of the di¡erent professions was strik-
ingly similar within a country. Key stages were
identi¢ed for professionalization in each country,
and there was found to be a sequential pattern
whereby one stage commonly followed another.
The identi¢cation of these stages and their
sequences thus led to the identi¢cation of di¡erent
historical stages for the UK and for Germany. As the
archival work and the interviews continued, these
stages were ¢ne-tuned.
The sequential stages of professionalization
developed for the UK and for Germany appeared
to be well substantiated. Obviously, in a paper of
this length it is impossible to convey in any detail
the collection and the interpretation of the historical
data that went into the development of these stages.
As can be seen, however, most of the professions
¢tted neatly into these sequential categories, and
displayed the characteristics listed. It thus seems rea-
sonable that the sequential stages and the country
characteristics faithfully re£ect the development of
the professions in the respective countries, and that
they re£ect the di¡ering relationships between the
state and the service labour markets in Germany
and the United Kingdom (see Tables 1 and 2; for
further details see the Appendix).
 COMPARISON OF THE DEVELOPMENT OF THE PROFESSIONS: UK AND GERMANY
Of course, the stages and the methodology can be
criticized. First, the stages and characteristics are
very broad. Breadth, however, is unavoidable and
necessary when dealing with institutional develop-
ments over hundreds of years. It could also be
argued that the stages are arti¢cial, providing
distinction where there is continuity, continuity
where there is distinction, and glossing over com-
plex economic, social, and political processes. This
is undoubtedly true. However, in order to demon-
strate the di¡ering routes to professionalization,
the di¡ering characteristics of this development,
and the di¡erent role of the state in the two coun-
tries, it is necessary to contrast and compare certain
features of the process.These features do not emerge
naturally from the researched histories but have to
be imposed in order to organize and analyse the
subject-matter. We found it useful to divide the
process up into these sequential phases and charac-
teristics so as to establish that, at least along these
lines, the development of the professions had
di¡ered quite markedly in the two countries. The
sequential stages and overall characteristics outlined
in this paper are at least transparent, and are thus
open to criticism, further testing, re¢nement, or
refutation.
Certainly, the development of the professions in
these countries could be rede¢ned, re¢ned, or re-
characterized from other perspectives. This is a
characteristic of pluralist social and historical analysis
generally.We do maintain, however, that although the
analysis of the professions can be cast in di¡erent
terms, it is intellectually and analytically useful to con-
sider the development of the professions in these
terms in order to demonstrate four things:
1. that most of the di¡erent established professions
within a particular country developed in a simi-
lar way, and this development displayed key
overall characteristics;
2. that for most of the di¡erent established pro-
fessions within a particular country, their
relationship with the state was similar;
3. that the typical development of the professions
di¡ered markedly between the United Kingdom
and Germany;
4. that the role the state played in the development
of the professions in both countries di¡ered
markedly between the United Kingdom and
Germany.
17
The Routes to Professionalization
United Kingdom
1. The occupation became full-time
The study found strong evidence that occupations
becoming full-time was a prerequisite for the pro-
cess of professionalization. This may seem rather
obvious, but it must be remembered that up until
the middle of the Industrial Revolution many
middle-class service occupations were (by modern
standards) part time, or carried out on an ad hoc
basis. The full-time service sector occupation is
historically an atypical phenomenon.
2. An articles system was established
Until the second half of the twentieth century, pro-
fessional training in the UK usually consisted of
learning by observing and copying the practices,
procedures, and techniques of established practi-
tioners. This system of training di¡ered markedly
from that which prevailed in central Europe, where
it was carried out through higher education. Over
time, the system of training in the United Kingdom
became re¢ned and formalized by the `articles'
system, under which `articled' assistants underwent
training by established professionals according to
the terms of a formal written contract.
3. Aprofessional association was formed
In order to obtain greater status and to be better able
to compete against less competent practitioners, a
professional association was formed and member-
ship was limited to the better-quali¢ed or more
prestigious practitioners. The membership of a
recognized professional association gave higher
status, and higher status usually resulted in higher
fee-earning possibilities. In this stage there were
commonly several competing professional associa-
tions, but in due course one usually emerged as the
leading association for the occupation in question.
4. Qualifying examinations were introduced
In order to stress high levels of competence,
professional associations introduced qualifying
examinations, often on a voluntary basis, but it was
soon mandatory for all new members.
18 MARK NEAL AND JOHN MORGAN
5. Political agitation for legal protection ofspeci¢c work areas
and/or Royal Charter
After establishing high levels of competence and
professional ideals, the professional associations
began to campaign for legal protection of their
profession or certain areas of their work, or at least
for recognition by a Royal Charter. A Royal Charter
was seen as giving su¤ciently high status to protect
members of the professional association from
competition from non-chartered practitioners. Full
legal protection and statutory regulation was usually
only introduced for professions unable to or
incapable of regulating themselves and where statu-
tory regulation was clearly in the public interest. In
those cases where statutory controls were intro-
duced, the regulations concerning professional
education, admittance to the profession, and control
of professional practice and discipline were gener-
ally delegated to the leading professional body or
bodies.
6. Academic routes to quali¢cation were established in
co-operation with higher education authorities
Academic routes to quali¢cation were established to
increase standards and status.These academic routes
were usually developed in combination with some
form of prescribed vocational training, carried out
after the academic stage and often gave partial or
complete exemption from the professional asso-
ciations' own qualifying examinations. University
education, followed by vocational training, gradu-
ally replaced the articles system. The professional
associations remained in control of the system of
professional education by means of course accredi-
tation, control of occupational training, and by
awarding the professional quali¢cation in question.
7. Rules were introduced to ensure continuous professional
development (CPD)
In the course of the twentieth century it became
recognized that professionals had to develop and
update their skills constantly in order to remain
professionally competent. There was a growing
awareness that there was no such thing as qualifying
for life.Various measures were taken to ensure there
was some form of CPD. Initially, this was on a volun-
tary basis, but in due course it became mandatory
and was subsequently monitored by the professional
body in question.
In addition to these temporal stages, there were
two key characteristics of professionalization in the
United Kingdom that are worth mentioning.
1. Professional associations remained responsiblefor
professional education
It was, and is, a characteristic of the development of
the professions in the UK that the professional asso-
ciations retained responsibility for professional
education. They still do to an extent, although
this autonomy is increasingly compromised by
European Union initiatives such as professional
transparency directives.
2. Professions were largely self-regulated
It has remained a characteristic of the evolution of
the professions in the UK that they are largely self-
regulating. This too is currently being undermined
by European Union institutions and initiatives,
particularly through professional transparency
directives.
Germany
The development of the professions in Germany
di¡ered radically from the pattern in the United
Kingdom, both in terms of the stages occupations
passed through in order to achieve professional sta-
tus, and the sequence of events that led to some
occupations becoming professions and others not.
Our research into the history of the professions
found that established German professions were
likely to have demonstrated the following sequential
phases in their evolution to high status.
1. The occupation became full-time
As was the case in the United Kingdom, the pro-
fessions in Germany developed initially through
specializations which led to a particular service
task becoming a full-time occupation. This similar-
ity between the two countries is understandable:
becoming full-time provides an occupation with
an increased and more sharply de¢ned public pro-
¢le; it entails routinization of the work, and a
relatively high level of commitment to the develop-
ment of the profession, either by the practitioners
themselves (as in the United Kingdom), or by those
responsible for administering the labour market (as
was the case in Germany).
 COMPARISON OF THE DEVELOPMENT OF THE PROFESSIONS: UK AND GERMANY
2. Local licensing was introduced
In order to understand the emergence of the profes-
sions in Germany, one must consider the key role
played by the civil service in German civil and eco-
nomic society. Unlike the situation in the United
Kingdom, the higher echelons of the German civil
service were graduate at the level of entry, had high
status, and were comprehensive, in that they a¡ected
all aspects of German society. Civil and economic
reforms in the German states were thus not the result
of popular movement or spontaneous organization
but were imposed by high-status civil servants pos-
sessing state power. The reforms to the labour
market in the nineteenth century are thus commonly
referred to as `reforms from above' (Nipperdey,
1987). The fact that the German civil service was so
e¡ective in introducing wide-ranging reforms has
had a lasting e¡ect on German political expecta-
tions, attitudes, and culture (Neal, 1998: 9^22).
One feature of this domination of German civil
and business life by the civil service was its interven-
tion into, and attempted `rationalization'of, German
labour markets. The key bureaucratic values of
`rationalization' and `control' lay at the heart of civil
service culture, leading the state to initiate various
licensing systems for the established and emerging
occupations.
3. Academic degrees were introduced by the state for areas it
considered desirable
The state was responsible for the university system,
and in the early nineteenth century universities gra-
dually expanded the subjects taught beyond the
original classics, introducing new academic degrees
for areas considered to be desirable for the state.
Macdonald (1995: 90^91) thus argues that the uni-
versity system in Germany and its close
relationship to the state and the administrative
classes played a crucial role in the development of
the German professions. The prevalence and in£u-
ence of the German university system is thus a key
di¡erence when comparing the respective develop-
ment of the professions in the United Kingdom and
Germany. As Macdonald notes, in the ¢rst half of the
nineteenth century Britain had six universities,
whereas the German states had around thirty (Mac-
donald, 1995: 90). Overall, the university systems in
Britain and Germany not only di¡ered in terms of
prevalence, power, and in£uence; they also di¡ered
19
in terms of their level of integration with the state,
and their role in training civil service administra-
tors ^ those who rationalized and controlled the
labour markets, and who prescribed and sanctioned
the kind of university training required for entry
into established or new professions.
4. Voluntary nationalprofessional associations were formed
Professional associations were formed on a local
basis in order to make regulations for the practice
of the profession in question, and to agitate for
legal protection of their area of practice. After
the foundation of modern Germany in 1871,
voluntary national professional associations gradu-
ally emerged with the primary aim of obtaining legal
protection and state regulation of the profession in
question.
5. Anational cameralistsystem was introduced
A system of professional chambers slowly emerged
which was a compromise between state control and a
limited amount of self-regulation. Initially this was
on the basis ofad hoc local chambers. However, in the
course of the late nineteenth and early twentieth
centuries a common camera list system for high-
status professions was gradually introduced
throughout the country, although the details varied
from one profession to another.
As with the United Kingdom, in addition to these
sequential stages, there were found to be two further
characteristic features of the development of the
professions in Germany.
1. It was a characteristic of the development of the
professions in Germany that the state remained
responsible for professional education and
admittance to the profession in question. Entry
to high status professions regulated by the cham-
ber system was usually by means of academic
quali¢cation and state examinations. Entrance
to the lower-status or semi-professions was by
means of becoming a sworn expert appointed
by the local chamber of industry and commerce,
the regulations for which had statutory author-
ity.With the emergence of the European Union,
however, the autonomy the German state has
over the professions has been challenged. As
with other member states, the German state
is now accountable to European directives
20 MARK NEAL AND JOHN MORGAN
concerning the harmonization of professional
quali¢cations.
2. It was a further characteristic of German profes-
sions that they were largely state-regulated.
Although high-status professions that were
organized on the cameralist system had some
measure of self-regulation of professional prac-
tice and discipline, the individual chambers
were subject to statutory supervision and the
regulations concerning professional practice
and discipline were also usually made by some
form of statutory order. The semi-professions
were regulated by the chambers of industry and
commerce and had virtually no self-regulation.
Once again, recent pan-European developments
have changed this situation. The power of the
German state over the professions has been
compromised by European harmonization
directives.
The Legacy of History and the
Professions
Such are the key stages through which similar occu-
pations in the UK and Germany have secured the
advantages of professional status. We have seen
how the sequence and the nature of these stages
has di¡ered, producing distinct forms of what we
could call professionalization. The di¡erences in
the ways professions have developed in these two
countries have in turn resulted in di¡erent kinds of
labour markets and di¡erences in the organization
of services in these two societies. In the UK profes-
sionalization has largely been spontaneous and self-
interested, whereas in Germany professionalization
has been the result of state intervention in the name
of rationalized and controlled labour markets.
Two questions thus arise: ¢rst, why have di¡erent
occupations followed similar paths to professional
status within these countries?; second, and relatedly,
why has the professional development of similar
occupational groupings di¡ered markedly between
these two countries?
During the examination of the social histories of
the various professions, it became apparent that
complex interrelationships between various aspects
of the di¡erent socio-economies in£uenced the way
in which the professions developed and were orga-
nized in the respective countries. It also become
apparent that these interrelationships di¡ered
markedly between the two countries.The following
sections outline the more important factors that
contributed to the prevalence of spontaneous pro-
fessionalization in the UK, and state-sanctioned
professionalization in Germany.
Spontaneous Professionalization in the UK
The United Kingdom moved slowly from a feudal
system under which the monarch virtually held
absolute power, to a parliamentary democracy with
a constitutional monarchy in the twentieth century,
a key development being the period in the 1660s
when the last vestiges of the feudal system were
eliminated (Lloyd, 1984). The development of the
British Empire and the fact that the Industrial
Revolution started in England led to the rapid
expansion of a wealthy middle class and the early
demand for all types of professional expertise, such
as legal advice in setting up commercial enterprises,
accountancy, and auditing work, which were able to
organize and professionalize at the national level.
The laissez-faire policies of successive British govern-
ments in the nineteenth century further enabled
and encouraged the emerging occupations to organ-
ize themselves in order to fend o¡ competitors.
Culturally, self-regulation of the emerging bodies
was simply expected by all parties, as there was no
precedent for state intervention and regulation of
occupations. For self-interested reasons, occupa-
tional groups were highly motivated to achieve
social closure: to gain self-determination, and to
ensure barriers to entry by related occupations. In
direct contrast with the German states, social status
in the United Kingdom thus did not come from
state recognition, but from being a member of
the relatively independent `professional' classes.
Establishing professional associations was seen as
gaining for members of an occupation an estab-
lished route to success, a `safe haven' from free
competition which would exert a downward pres-
sure on the price of their services.
Finally, Britain's island status was more favourable
to the growth of democracy than Germany's posi-
tion in central Europe, which had so often been
the battleground of Europe (Loch, 1984: 35). This
enabled the smooth development of nationwide
 COMPARISON OF THE DEVELOPMENT OF THE PROFESSIONS: UK AND GERMANY
independent professional associations, which were
not so readily regarded as subversive elements or
challenges to the power of the state. The dominant
size of London, together with the fact that it was the
seat of government and one of the ¢nancial centres
of the world, led to a natural concentration of the
professional associations and leading professionals
there.
State-Sanctioned Professionalization in
Germany
Germany was not united as a single country until
1871 and even then it was a federation of 25 indivi-
dual states, each having di¡erent political and
cultural characteristics. This made it impossible for
national professional organizations to evolve until
the late nineteenth century, and even then strong
regional di¡erences were maintained. Parliament
did not establish itself as the legislative authority in
Germany until 1918, following the abdication of the
Emperor. The twenty-¢ve German states which
formed the German Empire in 1871 thus had limited
forms of democracy. The rulers had wide-ranging
powers, sometime verging on absolute authority,
and they were supported by a well trained but
authoritarian civil service, a key factor in the state
development of the professions.
The powerful and authoritarian civil service was
largely the result of Napoleon's reforms in Germany
in the early nineteenth century, which closely
mirrored the new political structures of France.
Napoleon required the German states to introduce
similar reforms of administration and jurisprudence
as France in order to control both internal and
foreign a¡airs. These involved reforms of many key
institutions in the German states: the school and
church systems (which were placed under state con-
trol); the abolition of the feudal system; the
codi¢cation of the legal system based on the code
Napolëon and the establishment of expert ministries
supported by a professional civil service, as well as
the reformation of old universities and the founding
of new ones.
These moves became known as `reforms from
above' (Nipperley, 1987) as were the other wide-
ranging reforms introduced in the ¢rst half of the
nineteenth century in Germany at the instigation
of the civil service. The result was that bureaucratic
21
authority and constitutional government developed
hand in hand in Germany (Sheenan,1989) and social
reforms were the result largely of the civil service
rather than any popular movement (Nipperley,
1987).
The lack of general su¡rage in the German states
in the nineteenth century led to the popularity of
Vereine as a means of pursuing common interests.
These were organizations such as clubs and associa-
tions varying from local sports clubs to national
trade associations and professional bodies. They
were (and still are) regulated by a special law which,
among other things, required them to be registered
and to have their articles of association approved by
the authorities, thus a¡ording the authorities the
opportunity to control the spread and activities of
such organizations (Rueschemeyer, 1973). The lack
of a fully democratic parliamentary system and civil
rights was thus a serious deterrent to the develop-
ment of fully independent associations as were
common in the Anglo-American world in the nine-
teenth century. The reliance on reform from above
in Germany and the political fear of strong, indepen-
dent movements in£uenced decisively the way in
which the professions evolved there in contrast to
the laissez-faire and free-trade attitudes of nine-
teenth-century Britain. In Germany professional
practitioners were far more inclined to look to the
state to organize and regulate the professions.
The Emerging Context
The German experience was thus of a di¡erent type
to the process of professionalization in the United
Kingdom. Indeed, none of the occupations exam-
ined in the United Kingdom demonstrated a
process of development similar to that of the
German professions.
The reverse, however, was not the case. Some
elements typical of UK professions could be found
in the profession of actuary in Germany and were
also to be seen in the organization of German
chartered surveyors. Whilst the process of pro-
fessionalization in the UK and Germany has varied
considerably up to the present, this does not mean
that there could not be some changes to the
processes in each country in due course as a result
of the globalization of business and harmonization
22 MARK NEAL AND JOHN MORGAN
in Europe. Theoretically, this could lead to the UK
model for professionalization gaining ground in
speci¢c professions in Germany. However, it seems
more likely that European legislation will lead to
closer government regulation of the professions
throughout the EU. This will mean that at least
one aspect of German professionalization will be
adopted in the United Kingdom, namely growing
state regulation of the professions.
The strengthening of European Union institutions
is central to an understanding of contemporary
changes in the nature and administration of the pro-
fessions in Germany and the United Kingdom. The
key changes concern:
. the nature of the professions in member
countries;
. their relationship with the state;
. their relationship with similar professions in
other member states; and
. the ways in which occupations are seeking and
securing professional status.
Along with the free transfer of goods, true eco-
nomic and social union entails the free transfer of
skills and labour. An important feature of the crea-
tion of a single market is thus enabling people with
particular skills to use these skills anywhere within
the European Union. This being so, European
institutions have intervened in the labour markets
of individual member states to ensure that it is the
case.
The preferred way of achieving this objective so
far has been to enact mutual recognition (and
thereby transferability) of professional quali¢ca-
tions. A key initiative in this has been Directive 89/
48/EEC, which stated:
the Directive establishing a general system for the
recognition of higher-education diplomas awarded
on completion of professional education and train-
ing of at least three years duration. The basic
principle of the general system for the recognition of
diplomas is that a host Member State may not refuse
Community nationals access to a regulated profes-
sion if they are fully quali¢ed to exercise the same
profession in their Member State of origin.Within
the meaning of the Directive, a regulated profession
is a profession access to which is made subject to the
possession of a diploma by laws, regulations, or
administrative provisions (Europa, 1998).
This important intervention into European labour
markets has the e¡ect of undermining the autonomy
of professional bodies within member states.While
seemingly allowing such institutions to retain
responsibility for the administration, licensing, and
training of their members, it outlaws any attempt to
hinder the practice within that country of profes-
sionals who have been trained and licensed in other
member states. By insisting upon the mutual recog-
nition of professional quali¢cations, the Directive
thus ensures that professional institutions within
individual member states have to tolerate practi-
tioners who have not necessarily been trained in
the ways required for the achievement of profes-
sional status in that country.
This is a development that goes to the heart of
what it is to be a `profession', and why it is that
occupations have striven to achieve professional
status. As many writers have observed, an impor-
tant self-interested rationale for occupations
striving to achieve professional status has been the
achievement of `social closure' or `market closure':
the establishment of barriers to entry to the profes-
sion in order to secure and sustain a `haven' from the
pressures of a free market in services. Professions in
European countries have traditionally enjoyed
social closure from similarly quali¢ed professionals
from other countries. In the case of Germany,
professionals from other countries have been denied
the opportunity of working there by immigration
controls and state controls on the licensing of pro-
fessional services. In the case of the United
Kingdom, professionals from other countries have
likewise been denied the opportunity of working
by immigration controls and by the regulations of
the relatively autonomous professional bodies
themselves. In both cases, the professions in the
respective countries were `protected' from an
unwelcome swelling of their numbers (particular if
they were in private practice) and from a consequent
depression in their earnings. Prior to the strength-
ening of the European institutions, professional
bodies in rich member states thus enjoyed an
additional form of social closure sustained by immi-
gration and occupational regulations.
The intervention by the European Union institu-
tions has changed all that, and professions in
relatively rich countries now have to cope with the
free £ow of professional labour. This means that
 COMPARISON OF THE DEVELOPMENT OF THE PROFESSIONS: UK AND GERMANY
Greek doctors trained in Greece can now work in
Germany, British lawyers can work in Germany,
and German teachers or social workers can now
work unhindered in the United Kingdom. The
form of social closure sustained by immigration
laws and occupational regulations is, theoretically
at least, a thing of the past.
However, the transition towards a pan-European
free labour market in professional services has not
exactly been a smooth one. On 27 July 1998 the Eur-
opean Commission decided to start proceedings
against seven countries for breaking the regulations
laid out in Directive 89/48/EEC. In particular, the
Commission ruled that the German authorities were
infringing the new rules in the case of teachers,
through not recognizing external teaching quali¢ca-
tions such as the widespread `bac ‡ 2'. This ruling by
the Commission (and it was repeated in sixother cases
in other countries) is particularly signi¢cant, for it
challenges the control the German state has over the
administration, training, and licensing of profes-
sional teachers. Through the implementation of one
European directive, the close relationship between
professions and the state which developed over
hundreds of years, has been quietly revolutionized.
Likewise in the case of the United Kingdom, the
same kind of pressure will increasingly be brought
to bear upon autonomous professional authorities
who attempt to discredit, or who do not accept, pro-
fessional quali¢cations from other member states.
The hundreds of years of struggle, lobbying, and
organizing that resulted in the relative autonomy of
British professions will have thus been swept aside
in a matter of only ten years from the date of the
1989 Directive. Professional bodies, formerly used
to determining their own a¡airs, are now powerless
to stop foreign professionals appealing on the basis
of their foreign quali¢cations.
The emergence of the European Union has thus
altered the relationship between professions and the
state in both the United Kingdom and Germany. In
the United Kingdom, the freedom of the profes-
sions themselves to determine who and who is not
able to practise in their country has been under-
mined. Their laissez faire relationship with the
British state has been superseded by the jurisdiction
of an interventionist super-state.
The German state's ability to determine who is
able to practise professional services in that country
23
has been superseded (and indeed overruled) by the
European super-state.The same European Directive
has thus had di¡erent e¡ects on the professional
power structures within the respective countries.
To conclude, a recent initiative by the European
Union indicates that the processes of professional-
ization in Germany and the United Kingdom have
been changed for good. European Directive 1836/
93 e¡ectively unilaterally established a new pro-
fession ^ that of the `eco-auditor'. Since that date
the European Union has funded and supported the
establishment of pan-European professional quali¢-
cations for the new profession, and has actively
encouraged pan-European university links and
training schemes to support it. Within a very few
years both the educational and regulatory infra-
structure required for the growth of this new
profession will have been established. Signi¢cantly,
the profession was initially established as a response
to other European directives concerning the moni-
toring and assessment of the e¡ects of industrial
processes and products on the environment. The
new profession is, therefore, by its very nature
highly integrated with the emerging super-state.
Eco-auditing was founded by the state, funded by
the state, controlled by the state, and will remain
highly integrated with the state ^ indeed, part of
the job of the `eco-auditor' is the monitoring of
industrial processes and products such that they
meet EU standards.
Here, then, is a new version of `professionaliza-
tion from above' achieved within a very short time
period. It remains to be seen if this is the beginning
of a new more Germanic mode of European profes-
sionalization.
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Appendix
The tables show the results of the comparative
historical research which led to the identi¢cation of
 COMPARISON OF THE DEVELOPMENT OF THE PROFESSIONS: UK AND GERMANY
di¡erent stages through which occupations passed
to achieve their existing professional status, and of
general characteristics of these processes, which
show marked di¡erences between the United
Kingdom and Germany. As can be seen, the tables
act as a template which at once orders the ¢ndings of
the research, and which, when the tables are com-
pared, displays marked di¡erences between the
United Kingdom and Germany. As can be seen,
the development of most of the professions ¢ts the
generalized patterns of professional development
very well.
United Kingdom
In the United Kingdom, compliance for the profes-
sions examined averaged 83.4 per cent and varied
between 67 per cent and 100 per cent when taking
into account all elements of the model. When
CPD (Continuing Professional Development) was
excluded, compliance averaged 87.1 per cent and
varied between 69 per cent and 100 per cent. Of the
nineteen professions examined, no less than eleven
showed a maximum of only one deviation from the
model.
The common pattern revealed by this investi-
gation was thus quite striking. Thirteen of the
nineteen professions originally used a system of arti-
cles in order to train new entrants to the profession.
In those cases where a system of articles was not used
it was because these were professions that evolved at
a time when the articles system itself was starting to
fall into disuse at the beginning of the twentieth
century.
Of the nineteen professions examined, seventeen
possessed Royal Charters, the only exceptions being
barristers and dentists: barristers already enjoyed
high status in the nineteenth century when it
became usual for emerging professions to apply for
Royal Charters in order to obtain higher status;
meanwhile, dentistry was not regarded as a fully-
£edged separate profession in the United Kingdom
until 1878 and, until then, came under the aegis of
the Royal College of Surgeons, which itself
possessed a Royal Charter.
All the professions examined had an academic
route to quali¢cation. However, with the exception
of barristers, solicitors, surgeons, and general practi-
tioners these were all introduced in the course of the
25
twentieth century when the academic route to qua-
li¢cation gradually replaced the older system of
articles that was coupled with professional examina-
tions. It is interesting to note that all the professions
examined in the United Kingdom originally con-
ducted their own qualifying examinations.
The two professions showing the least com-
pliance were those of chartered architect and
optometrist.The latter is an exception to the occupa-
tions examined in that most optometrists today are
employees of large companies and also in that it
cannot, perhaps, be regarded as a typical high-status
profession. The chartered architect, on the other
hand, would normally be regarded as being a
member of a high-status profession. The main rea-
sons for the relatively high level of non-compliance
are that the Royal Charter was granted sixteen years
before professional examinations became manda-
tory; the leading professional association ^ the
Royal Institute of British Architects ^ is only partly
responsible for education; and the profession is not
largely self-regulating. It is thus atypical of the pro-
fessions examined in that the statutary regulation of
this profession has not been delegated to the leading
professional association.
Finally, the medical professions in the United
Kingdom were also something of an exception in
that they were to a large extent nationalized by the
National Health Service Act 1947 and were, there-
fore, subject to more state controls than would
otherwise have been the case. However, prior to
this they followed the general pattern more closely,
in that even where there was statutory regulation, the
leading professional bodies were given considerable
powers or were involved in the consultative process.
Germany
So far as Germany is concerned, average compliance
at 77.8 per cent was slightly lower than for the UK
model (83.4 per cent). The main reason for this is
that some of the professions examined had not yet
evolved into what could be considered high-status
professions, i.e. those professions that had a national
system of professional chambers, state education
and admittance, and general state regulation. It can
be seen fromTable 2 that these professions were ones
that largely developed in the late nineteenth century
26 MARK NEAL AND JOHN MORGAN
or were not yet regarded in Germany as separate
identi¢able professions.
The six professions with the lowest rate of
compliance (28^57 per cent) were those of sworn
valuer, optometrist, psychologist, actuary, phy-
siotherapist, and insurance broker. The sworn
valuer is today not always regarded as an indepen-
dent or separate profession in Germany and has no
generally recognized route to quali¢cation. The
occupation of insurance broker is regarded as a com-
mercial activity in Germany, and the professions of
actuary and physiotherapist have only recently
emerged as organized professions.The sworn valuer
is not always regarded as an independent or separate
profession and is often an occupation carried out by
architects and building engineers in their general
practice. Optometry is organized as a typical trade
in Germany, although there has been an academic
route to quali¢cation since 1982. The occupation of
psychologist did not emerge as a separate profession
until the end of the nineteenth century in Germany
and is still not organized in the same way as other
traditional professions.
These six occupations were similar in that
they were seen to carry low status or be semi-
professional. If they were excluded, the remaining
¢fteen professions examined showed an average
compliance of 90 per cent, six showing 100 per
cent compliance. Eleven of these ¢fteen professions
show a maximum of one deviation from the model.
The thirteen high-status professions obviously
showed remarkable similarities. Except for patent
lawyers, all these professions were originally subject
to some form of local licensing.With the exception
of auditors and tax advisers there was an academic
route to quali¢cation and even in these two cases
an academic degree shortened the period of training
required. Except for land surveyors and controlling
engineers there was a national system of professional
chambers. With the exception of auditors and tax
advisers, the state was responsible for providing
professional education. All thirteen high-status
professions were, of course, largely state regulated
and the state was also largely responsible for profes-
sional education and entry into the profession.
The examination of these nineteen professions in
Germany demonstrated that, in contrast to the situa-
tion in the United Kingdom, professions which
were not largely state regulated were generally frag-
mented. The German state played a highly
interventionist role in the initiation, regulation,
and administration of professional bodies com-
pared to the laissez faire attitude of the British state
towards the development of the professions.
Authors' Address
Organization Studies Research Group, Aston Business
School, Aston University, Aston Triangle, Birming-
ham, B4 7ET, UK.
Manuscript received: August 1998.