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• Some countries require such positions as teachers,

lawyers, civil servants or soldiers “to be filled by
citizens and explicitly exclude migrant workers for
these”;

• Differences in language, culture and social

acceptance “create practical barriers”; and
• MRA negotiations done mainly at the bilateral

level (not regionally) and there “loopholes for
implementation”.

Another study, this time by Philippa Dee of the
9
Australian National University, was blunt by raising the question
if AFAS has “a bite”. She observed there are gaps between
ASEAN commitments and “actual practice” in the service

industries prioritized by ASEAN for liberalization. The gaps are
widespread in air transport, telecommunications and banking,

although there is significant “reform” in accountancy. Just like
in the trade in goods where NTBs are a major stumbling block,
“domestic regulation” (such as taxation and “necessity tests”

for employment of foreign service personnel) is generally hazy,
if not non-transparent, in many member countries.

9
Dee, P., 2013. Does AFAS have a bite?, Jakarta: Economic Research Institute
for ASEAN and East Asia.

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