Citizen Space

In October 2023 ARB’s Board approved the introduction of three new fees to cover the costs of accreditation. This accompanied reforms to the initial education and training of architects, including the competency outcomes required of aspiring architects, new standards for learning providers and a new risk-based accreditation methodology. The new fees were made possible by changes to Government legislation, which were consulted on in 2020. 

The new fees have been set to recover the cost of ARB activities, including the management and administration entailed in quality assurance and decision-making, and the work of the new Accreditation Committee, which includes visits. 

We asked for views on the regulatory impact of the fees as set out in this document. Whilst we are not able to change anything that is set by legislation, we welcomed feedback on the following:  

• Anything further that ARB should consider regarding how the fees are to be paid. For example, whether there is anything you would like us to know about the timing of learning provider budget setting and the timing at which we invoice for the fees.​  

• Anything in the structure of the fees that could have a disproportionate impact on particular groups of students or other individuals, in light of our commitment to Equality, Diversity and Inclusion.​  

• Any further regulatory impacts to which you would like to draw our attention.

We received 33 unique responses, with 12 official responses from learning providers or other organisations, and 21 additional responses from individuals in the sector but not representing their organisations. 

While some suggestions were things we could not consider, those that we could were focused around three themes: 

Timing – to change the time of year at which we invoice. 

Changing the time of year at which we invoice was raised by four respondents. Three suggested ARB should consider the timing of budget setting of academic year for learning providers, and one suggested that they would need more time to adapt to the new fee system. 

Phasing or delaying the fee 

One mitigation suggested was to phase or delay the introduction of the fees, changing how much learning providers would have to initially pay. Respondents argued that this would make the fee more manageable. For example, one respondent suggested that “an incremental and phased introduction of ARB fees (starting at a much lower rate) would be beneficial, in terms of both financial manageability for schools of architecture, as well as in establishing a better working relationship between these Schools and the ARB.” 

A related suggestion was that the fee be introduced after the transition to the new Competency Outcomes and when Part 1 accreditation has ceased. 

Scaling the fee  

This was raised by 14 respondents. Learning providers often stated that a one-size-fits-all fee is inappropriate, mentioning that fees should not be the same for every organisation. Respondents suggested that the fee should be scaled to the size of the learning provider. These included requests to consider the number of students, the income of the institution or the number of accredited qualifications being provided. For instance, one official response from an accredited learning provider said “the ‘covering costs’ concept needs to carefully consider whether all Schools are charged the same or is based on the number of prescribed programmes”. 

Another official respondent included “sliding scales for fees based on School size/number of courses” among their list of recommendations. 

Other requests  

Some respondents suggested things that ARB will not be able to consider because they were based on a misunderstanding of the cost recovery basis of the fee. For example, one respondent suggested the fee could be used to create a stipend returned to universities to support certain activities. One also compared ARB’s fee level to other regulatory bodies, saying that ARB’s fees should be aligned with these. 

Some learning providers requested more information about how the fee is calculated, beyond the detail published on our website as part of the engagement exercise. 

Finally, some also wanted more detail about what they will need to do in future, and said they found it hard to respond to this exercise without full details about the data they’ll need to produce for their qualifications to be monitored against our new Standards for Learning Providers. 

Additional engagement 

In addition to the feedback we received through formal responses to our questions, we also met a number of providers and continued to discuss a range of issues with SCOSA with feedback consistently referencing a desire to review the timing, scale and structure of the fees due to the potential impact on learning providers. These formed part of the feedback to the Board. 

ARB’s Board considered the survey responses and wider feedback from learning providers at its meeting on Wednesday 28 February.  

At this meeting it decided to make changes to the new fees. These include changes that will apply to both the fees for new qualifications and for annual accreditation. 

You can read more about these changes here. 

From October 2023 to December 2023, we launched a consultation on changes to ARB’s plagiarism policy. 

ARB has been operating a zero-tolerance policy towards “plagiarism and cheating” but we wanted to update the policy to improve its fairness and consistency. We also wanted to clearly emphasise the standards of honesty and integrity those who join the Register are expected to uphold. 

We asked for views on proposed updated policy as set out in this document, along with accompanying changes to procedures for the Prescribed Examination and the UK Adaptation Assessment. The proposed new plagiarism policy continued to treat plagiarism as severe but improved our approach in four key areas: 

• A clearer new definition of what we consider to be plagiarism. 

• A clearer declaration for applicants. 

• A clearer process for examiners and ARB staff involving a new standardised approach to identifying plagiarism. 

• A new range of discretionary penalties that escalate based on the severity of the offence.

We received nine responses to the consultation. The majority of respondents (five) were academics. Three were registered architects and one was an architecture student. 

Respondents agreed overall with each of our statements and there were no significant concerns that would mean needing to change the substantial elements of the policy. Every response was read and analysed, and ideas and suggestions identified by respondents were incorporated into an updated version of the policy. 

ARB’s Board considered suggestions and feedback from the consultation at its meeting on Wednesday 28 February 2024. It approved the updated policy with some additional amendments to provide further clarity on the original intent of the policy. These are: 

• Clarifying that plagiarism means someone has not demonstrated their competence or knowledge in a particular area because their evidence for doing so was plagiarised, rather than them having an overall lack of competence or knowledge. 

• Removal of the word “grade” to better match the Prescribed Exam, UK Adaptation Assessment or any future assessments.

• A change to reduce potential confusion around references to 'presenting someone else's work as your own'. This may not have clearly included generated plagiarism that wouldn’t necessarily be from a person (as “someone else”). The new policy instead refers to 'the work of a third party as your own'. 

An updated version of the new policy can be accessed here.

The new policy is not yet in effect and ARB will now work to implement it later this year. When the policy is in place, it will be clearly communicated to any applicants to whom it would apply. 

From February 2023 to May 2023, we launched a new consultation on our approach to the way architects are trained and educated. We consulted to invite views on a new regulatory framework, new competency outcomes, new standards for learning providers and new plans for quality assurance. We proposed that:

• The regulatory framework for educating and training architects should change from the current approach (Parts 1, 2 and 3) to require only two accredited qualifications.
• Qualifications accredited by ARB should be based on a new set of competency outcomes, so that they are based on what architects can do, not what they are taught.
• Clear standards should be required of universities and all learning providers delivering ARB-accredited qualifications.
• ARB should introduce a new proportionate and risk-based quality assurance of qualifications.
• Should our proposals be approved, anyone setting out to become an architect from September 2027 onwards should be trained and educated through the new, improved framework and assessed using the new competence outcomes. We published a draft transition timetable as part of the consultation.

We received 672 unique responses, demonstrating a wide reach across different roles, regions, and respondent characteristics. Most responses (59%) were from registered architects (396). One hundred and ten of these (16% of total respondents) were also academics. We also received responses from students, other built environment professionals, member of the public, and other types of respondents including international architects, architectural technology students, and retired architects.

The framework
There were mixed views about the proposed regulatory framework, with 40% agreeing that it would meet our aim and 43% disagreeing. More respondents agreed that our proposals will improve access (43%) than disagreed (36%). In addition to this, many respondents agreed that the proposals would enable innovation and flexibility, as well as increase access for underrepresented groups.

Professional practical experience
The majority (60%) disagreed with our proposal to remove the minimum duration of practical professional experience and one in ten said they found it unclear.

Competency outcomes
In our proposed new structure, skills, knowledge, experience and behaviours are defined through five competency areas: Professionalism and Ethnics, Design, Research and Evaluation, Contextual and Architectural Knowledge, and Management Practice and Leadership. There were high levels of support for all the proposed competency areas, ranging from 74% (Professionalism and ethics) to 64% (Research and evaluation). Furthermore, we received a variety of opinions regarding the competencies' content, as well as numerous beneficial suggestions for drafting changes to improve clarity and feedback from respondents about the number of competencies presented, along with suggestions for additional competency outcomes.

Accreditation and transition
More respondents agreed than disagreed with each proposed standard for learning providers, from 52% (Educational content) to 43% (Human resources). The most commonly expressed opinion (provided by 17% of respondents) on the transition arrangements was that we should be more explicit and provide more clarity about our plans.

ARB’s Board has discussed the analysis and considered the next steps alongside the aims of our reforms and our statutory remit, and has made the following decisions:

The framework
Important modifications will be made to the regulatory framework before we introduce it, to make sure it upholds standards whilst also removing bureaucracy and opening up the potential for new routes to joining the Register of Architects. Respondent views on the framework were mixed, but those who disagreed were not in alignment about an alternative. We will issue new guidance to learning providers about the appropriate learning and experience of those seeking to access the new Masters qualification. Our proposals do not negatively impact student access to funding.

Professional practical experience
We will revise proposals for professional practical experience. We have learned through the consultation that removing the minimum duration will not address the problems that arise for those looking to gain the experience, and could have the unintended consequence of weakening the standards of the architects’ profession. We will consider short-term modifications like additional flexibility about the types of experience which are deemed relevant.

We will also appoint an independent Commission to develop new recommendations for the Board. We cannot solve all the problems with practical experience, but we want to take the lead in helping to improve access to it, and the experience of future architects. The Commission will help us identify how best to do that. It will run alongside our overall timetable and will not delay it.

Competency outcomes
We’ll make some drafting amendments based on useful feedback, and publish the final versions this autumn.

Accreditation and transition
We will publish the final version of the standards this autumn. We will establish a stakeholder group to give us agile feedback as the transition progresses.