Fees for accredited learning providers: your views

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.