Studying Law in Europe: National Bar Systems vs England's Common Law Track
By Muntasir Minhaz • Published Apr 03, 2025 • Guides, Study in Europe, Fields of Study
England and Wales let you become a solicitor through one national exam route (the SQE) after any degree, while most of continental Europe still requires a dedicated law degree followed by a state-run bar exam and a supervised traineeship. Passing the bar in one country does not automatically qualify you to practice in another, though EU rules give lawyers a path to work across borders.
🎓 England and Wales: SQE1 and SQE2, plus 2 years of qualifying work experience (QWE), open to graduates of any subject
💶 SQE1 costs £1,934 and SQE2 costs £2,974 for 2025-26 sittings
Germany: a 5-year law degree, the First State Exam, then a supervised Referendariat before the Second State Exam
France: a law master's degree, the CRFPA entrance exam, then 18 months at bar school before qualifying as an avocat
📩 Under EU rules, a qualified lawyer registers and practices under their home title in another EU or EEA country, then integrates fully after 3 years of regular practice there
Two starting points for one profession
Continental Europe and England and Wales train lawyers in different ways. Civil law countries such as Germany, France, Spain and Poland treat law as an undergraduate subject you study on its own, then follow with a state exam and a traineeship set by the government or the bar. England and Wales run a common law system where you study any degree subject, then complete a national assessment called the Solicitors Qualifying Examination (SQE) plus supervised work experience.
Both routes lead to a licensed lawyer, but the exams test different things. Civil law exams focus on codified statutes and how courts apply them. The SQE tests functioning legal knowledge across practice areas plus practical skills such as client interviewing, advocacy and legal drafting.
How continental Europe qualifies lawyers
Germany runs one of the strictest systems in Europe. You study law for about five years and sit the First State Exam (Erste Juristische Prüfung), which combines university assessments with a state-set exam. Passing lets you start the Referendariat, a supervised legal traineeship split across courts, prosecution, a law firm and public administration, ending with the Second State Exam. Only after both exams do you earn the title Volljurist , a fully qualified lawyer able to work as a judge, prosecutor or attorney.
France separates the academic and professional stages more clearly. You need a law master's degree (M1 or M2) from a French university, or an equivalent European law degree, to sit the CRFPA entrance exam. Passing enrolls you in 18 months at a regional bar school (CRFPA ), split between coursework and two 6-month traineeships, before you qualify as an avocat. You get 3 attempts at the entrance exam.
Most other continental systems follow the same pattern: dedicated law degree, then a state or bar-run exam, then supervised practical training before you gain full rights of audience.
England and Wales: the SQE route
The Solicitors Regulation Authority (SRA) replaced the old law degree plus LPC route with a single national assessment. You need to pass SQE1 and SQE2 and complete 2 years of qualifying work experience (QWE), which happens in up to 4 different organisations and in any order relative to the exams.
SQE1 tests legal knowledge through multiple-choice questions across the core practice areas. SQE2 tests practical skills such as advocacy, drafting and client interviews. Fees for 2025-26 sittings are £1,934 for SQE1 and £2,974 for SQE2, on top of any preparation course you take.
Unlike the continental model, you do not need a law degree to sit the SQE. Graduates from any subject qualify, which is why England and Wales attract more career-changers into law than most of continental Europe.
What actually crosses borders
Passing a bar exam in one country does not make you a lawyer everywhere else in Europe. Within the EU and EEA, the Lawyers' Establishment Directive 98/5/EC lets a qualified lawyer register with the competent authority in another member state and practice under their home professional title. After 3 years of effective and regular practice there, or by passing an aptitude test, that lawyer integrates fully into the host country's profession.
This route does not extend to England and Wales lawyers since Brexit. A solicitor qualified in England and Wales is now treated as a third-country lawyer when applying to practice in an EU member state, and has to meet whatever recognition rules that state sets for non-EU qualifications. The reverse applies too: an EU-qualified lawyer moving to England and Wales has to meet the SRA's own requirements for foreign qualified lawyers, which usually means sitting some or all of the SQE.
Choosing a track
| System | Entry route | Core assessment | Practical stage |
|---|---|---|---|
| England and Wales | Any degree subject | SQE1 and SQE2 | 2 years QWE |
| Germany | 5-year law degree | First and Second State Exam | Referendariat |
| France | Law master's degree | CRFPA entrance exam | 18 months bar school |
If you want to practice mainly in one civil law country, study law there from the start since the degree and the bar exam are built around each other. If you want flexibility to enter law after studying something else, or plan to work across common law jurisdictions, the SQE route in England and Wales gives you that opening. If cross-border EU practice matters to you, factor in that Directive 98/5/EC only works between EU/EEA states, and check the host bar's rules before assuming your qualification travels.