US licensed architects, benefitting from NCARB’s Mutual Recognition Agreements (MRAs) with other national licensing bodies, have long been able to pursue reciprocal licensure in Canada, Mexico, Australia and New Zealand, and vice versa. Early this year the United Kingdom has been added to the list after a similar agreement with the ARB was finalized on 16 February, enabling US or UK licensed architects to explore professional practice opportunities across the Atlantic. [1]

This new MRA comes on the heels of the UK’s exit from the European Union and its single market system. One part of this, the automatic recognition of professional qualifications (Directive 2005/36/EC), requires the automatic recognition of individuals licensed in certain regulated professions - architects, as well as doctors, dentists, nurses, and pharmacists - across all EU states. With the UK now no longer party to this arrangement, it has rapidly developed individual agreements with other countries. Soon after the MRA with NCARB, the ARB entered a shared MRA with the Australian and New Zealand authorities (AACA and NZRAB respectively) on 15 March. While these developments are still recent, it illuminates the policy direction that the UK is adapting and offers a glimpse into the different ways architecture is regulated.

While lacking the geographic commonality of the EU single market, the UK’s new emerging network of MRA partners shares other traits. Culturally and linguistically, all share historical roots as former Crown colonies and use English as the standard language. Fluent communication in the profession is obviously a requirement, a sentiment shared in other EU jurisdictions. France’s Ordre des Architectes requires, for example, all educational institutions to conduct instruction entirely in French to be eligible for accreditation, a requirement arguably going against the spirit of the EU single market.

Delving into the licensure paths themselves, the requirements can be broadly categorized into education, experience, and a form of final assessment of competency. Each has similar requirements for the first two: Around five years study in an accredited institution and two years work experience under an experienced architect. To the latter point, a varied but stringent use of standardized examinations and assessment interviews is shared. A brief overview of each jurisdiction’s standard path to licensure follows:

US NCARB National Council of Architectural Registration Boards

Education: B. Arch or M. Arch (5-6 yrs)

Exp record: AXP Architectural Experience Program (3740 hrs)

Examination: ARE Architect Registration Exam - six-part computerized exam

Interview: (per jurisdiction) [2]

UK ARB Architects Registration Board

Education: RIBA Part I + II (5-6 yrs)

Exp record: Part III PEDR Professional Experience Development Records (2 yrs)

Examination: Part III written or verbal exam (content and length per institution)

Interview: Part III assessment panel interview [3] [4]

Australia AACA Architects Accreditation Council of Australia

Education: M. Arch (5 yrs)

Exp record: APE SoPE Statements of Practical Experience (3300 hrs)

Examination: APE NEP National Examination Paper - computerized exam

Interview: APE assessment panel interview [5]

New Zealand NZRAB New Zealand Registered Architects Board

Education: M. Arch (5 yrs)

Exp record: project record forms and case study evaluation (5250 hrs)

Examination: N/A

Interview: Professional Conversation assessment panel interview [6] [7]

This similarity in licensure requirements is in stark contrast to the EU member states and their respective licensing bodies. While higher education has been standardized in the EU via the Bologna Process, resulting in transferrable bachelor’s and master’s degrees across the board, the other requirements have not. For example, Portugal requires one year of trainee experience [8], whereas Austria requires three [9]. Spain has none [10]. Germany has no exam or interview requirements. [11] [12]

The UK’s move from the EU single market to individually negotiated MRAs with similarly stringent licensure requirements lends insight into the ARB’s concerns and vision for future reciprocity policy. Even with the new MRAs, the UK still requires foreign applicants via these paths to undertake the UK Adaptation Assessment, a shorter interview to ensure a working knowledge of UK practice, further ensuring legal and practical competency.

Turning back stateside, NCARB has a varied approach to licensure reciprocity; it similarly has MRAs commonly with Australia and New Zealand, with the additional requirement of 6000 hours of post-licensure professional experience for all applicants via this path. Additionally, NCARB is party to the long-standing Tri-National Agreement comprising ROAC of Canada and FCARM/CONARC of Mexico [13], acknowledging the importance of geographical proximity to architectural business and practice. To that point it reflects the EU’s system. A brief overview of the standard path to licensure in both follows:

Canada ROAC Regulatory Organizations of Architecture in Canada

Education: M. Arch (5 yrs)

Exp record: IAP Intern in Architecture Program (3720 hrs)

Examination: ExAC Examination for Architects in Canada - written exam (NCARB ARE accepted)

Interview: (per jurisdiction)

Mexico CONARC / FCARM Federación de Colegios de Arquitectos de la Republica Mexicana

Education: ANPADEH accredited B. Arch (5 yrs)

Exp record: N/A

Examination: N/A

Interview: N/A

While Canada’s requirements closely mirror those of the US (so far as to accept NCARB’s ARE exam) thus allowing for a more streamlined MRA between Canada and the US [14], Mexico’s comprise solely a professional undergraduate degree, reflecting a different legal role of the architect in the construction industry (where more authority and responsibility is held by the civil engineer). But regardless of this discrepancy, all applicants utilizing the MRA are required to first achieve and prove 10 years of post-licensure professional experience in their home country (including 2 of which must be in responsible control of architectural practice), then pass a panel assessment interview with the host country - in the host language - to thoroughly assess both professional and cultural competency. [13]

The Tri-National Agreement addresses some of the concerns of the no-holds-barred automatic reciprocity used in the EU by weighing post-licensure experience very heavily, as well as giving the host country greater deciding power via assessment interviews. Indeed, a preliminary draft of a US/EU MRA from 2005 (which was not pursued further) also stressed greater experience requirements for US and EU licensed architects, fourteen years of education and professional experience, to pursue reciprocity.

Natural concerns regarding applicability of national licensing standards to other countries, as well as professional, cultural and practical competence of applicants looking to practice elsewhere, can be assuaged in different ways. Jurisdictions can limit agreements to parties with similar licensing paths and assessments. They can also ensure that only those with much experience in the profession can make the jump. With the further globalization of the profession and the number of mutual agreements with other states only increasing - the UK is also considering re-establishing reciprocity agreements with the EU. The trend of current agreements sheds some light into what we can expect in the future.