We asked, you said, we did

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.

From September 2022 to January 2023, we consulted to invite views on a draft of the guidance before it is finalised. The consultation asked for feedback on key parts of the guidance, including the activity-based nature of the scheme, suggestions on mandatory topics, views on the reflective statement, as well as the inclusivity of the scheme and further recommendations.

We received 1,350 unique responses in total. Most responses (96%) were from registered architects (1,302) including registered architects who are also academics (65). We received responses from people across the country and the profession, with responses from different sized practices and architects at various stages in their career.

A majority (58%) of respondents agreed that recording activities is a good way of measuring CPD that has been undertaken. Sixteen percent of respondents strongly agreed and 42% agreed with this draft proposal. Twelve percent disagreed, 19% strongly disagreed and the remainder neither agreed nor disagreed.

ARB recommended that architects carry out a minimum of eight CPD activities over the year (which will include activities carried out in respect of mandatory topics). Views on this proposal were split, with slightly more respondents agreeing (44%) than disagreeing (41%).

Fifty-five percent of respondents made recommendations for mandatory topics, with the most popular recommended topics from respondents being regulatory changes (24%), sustainability (22%) and safety (21%). These topics have also been raised with ARB through previous engagement and research exercises. 

Overall, respondents did not support the proposal for a reflective statement (68%), wherein an architect would need to discuss how their chosen activities supported their development. The most common concerns around the requirement of reflective practice were that it was too bureaucratic (32%) and took time away from fee-earning work (18%).

Two-hundred and eight (15%) respondents were recorded expressing a concern about the scheme relating to money, disabilities, caregiving responsibilities, online access, location or gender. Affordability and the exclusion of those on lower incomes was the most common concern, raised by 65 (5%) respondents. 

The full report can be accessed here. 

Following a positive response to both the principles underpinning the scheme in our last survey, and to the activities-based nature of the scheme we proposed in this consultation, ARB intends to introduce the outcomes focused CPD scheme. This means that architects will need to carry out CPD activities every year and confirm they have undertaken it when they pay their retention fee in order to remain registered. Architects are free to identify their own CPD activities. If an architect has developed professionally and can apply what they have learnt to their practice, then it can be considered continuing professional development.

There will be no minimum number of activities that an architect must complete. ARB will suggest, not but mandate, that architects undertake eight activities a year.

Based on feedback from respondents on mandatory topics, ARB will make it an initial requirement of the scheme that architects carry out CPD on sustainability and building safety in a way that is relevant to their practice.  development areas when the scheme launches. We will issue guidance to support architects in doing so, and work with professional bodies to signpost knowledge sources. We will we review the CPD scheme as it embeds to better understand its effectiveness, and consider whether different areas of architecture should be the subject of mandatory CPD in the future.

Following feedback on the equality, diversity and inclusion implications of the scheme, we will develop and test the online portal so that it is accessible and we will offer reasonable adjustments. Basing the scheme on activities and giving architects the flexibility to define their own activities makes the scheme inclusive; architects can opt for activities based on the best learning style for their needs and their practice, and that need not cost money.

A reflective statement is a crucial outcome-focused aspect of the scheme. Concerns from respondents focused on how this requirement would be implemented rather than its underlying purpose and benefit. ARB will retain the reflective statement but will consider how to improve our guidance on the statement so that its value is better understood, and so that it is straightforward for architects to complete. We will also pilot the scheme so we can better understand how it operates in practice, and consider whether suggestions made by consultees would improve the process.

ARB will finalise the scheme based on the conclusions above and feedback we have received from our pilot study. We will publish updated, final guidance by the end of 2023. The scheme is expected to be launched in 2024, becoming mandatory for registered architects from January 2025. We will share further information on the detail of the scheme and the result of the pilot is planned for later in 2023.

• Changes to the law through the Building Safety Act 2022 require ARB to establish a new Appeals Committee.
• The scope of decisions that the Committee can consider is set in legislation but ARB is able to set rules on the Committee's composition and functioning. 
• In October 2022, ARB invited views on proposed rules to establish the Committee. These covered how an individual can appeal to the Committee and the procedure for how it should function.
• The survey comprised of four questions.
• Two questions featured ‘closed’ multiple-choice elements, with the remaining two using solely an ‘open’ free-text element where respondents could give more insight into their views. The questions are reproduced in order below:

Question 13: Status of the Appellant while the appeal is being considered

The proposed rules would mean that:

• For appeals against an initial decision involving an application for registration, the Appellant will remain unregistered pending the outcome of the appeal.
• For appeals against an initial decision to remove someone from the Register under the new competence (CPD) scheme, the Appellant will remain on the Register pending the outcome of the appeal.

Do you agree with this approach?

Respondents were invited to select one of the following options: Strongly agree, Agree, Neither agree nor disagree, Disagree, Strongly disagree.

Respondents also had the opportunity to explain the rationale for their response in an open text box. 

Question 14: Appeal Fee

The proposed rules include that ARB will set a fee that must be paid by an individual before their appeal can be considered. This would be set annually by the Board, on a purely cost recovery basis, and stated on ARB’s website.

Do you agree with this approach?

Respondents were invited to select one of the following options: Strongly agree, Agree, Neither agree nor disagree, Disagree, Strongly disagree.

Respondents also had the opportunity to explain the rationale for their response in an open text box. 

Question 15: Is there anything within the proposed rules that could have an impact on ARB’s commitment to equality, diversity, and inclusion, or have a positive or negative impact on anyone with particular protected characteristics?

Question 16: Do you have any other comments about the proposed rules?

• We received 48 unique responses to the consultation.
• 96% of respondents to the survey were registered architects.
• The majority of respondents supported our proposed rules.
• There were no significant recurring themes raised that would impact the inclusivity our proposed rules.

We produced an analysis report that summarised responses to the survey. This was discussed at ARB’s Board meeting on 15 February 2023 and approved for publication. This report is available here.

Alongside the consultation, we identified technical changes that would help to clarify the status of Committee members by reflecting developments to the status of ARB’s workers. These changes will also mean a more efficient and transparent approach to membership of ARB’s Professional Conduct Committee and Appeals Committee. These two committees cover separate areas of decision-making.

In line with requirements of the Architects Act 1997, ARB has also consulted the Secretary of State on the Rules regarding the Committee’s composition.

At its meeting on 15 February, ARB’s Board approved the updated Rules for the Committee and its functioning. We will now implement the Rules to establish the Committee and, when the Committee is established, we will begin to inform individuals as part of any decisions we make that are eligible for appeal.

• The way we educate and train architects in the UK needs to change. The current system has produced thousands of excellent architects, but it’s also created significant barriers to some people becoming architects at all. We have a vision of how we might modernise the system, by developing a regulatory model that focusses on the outcomes required of an individual at the end of their initial period of education and training.
   
• We believe that the most important factor is what a newly qualified architect should be able to do – not how they got there. This means that we are open to considering different routes to registration, particularly those which might widen access to the profession.
   
• We invited views on our proposed vision for how to modernise initial education and training in order to achieve this.
   
• The survey comprised of five questions.
   
• Two were ‘open’ questions inviting a written response, and three were a mixed format in which respondents could answer a multiple-choice element to indicate the extent to which they agreed or disagreed with our proposal and also share their views in a written response. The questions are reproduced in order below:

Question 10: Chapter 4 of the discussion paper sets out the evidence we have analysed to date, and the conclusions we’ve reached. Is there anything you believe is missing from these conclusions, that we should also take into account as we start developing the outcomes-based approach?

Respondents were invited to write a response into an open text box.

Question 11: Chapter 5 of the discussion paper sets out the vision for our new regulatory approach. To what extent do you agree with our vision? Please feel free to explain your view, and make any suggestions as to what is missing.

1. Public
2. Profession and employers
3. Institutions
4. Future architects
5. Regulatory

Respondents were invited to select one of the following options for each vision: Strongly agree, Agree, Neither agree nor disagree, Disagree or Strongly disagree. Respondents were also invited to write a response into an open text box.

Question 12: To enable institutions to innovate and to promote diversity, we think that the structure needs to change from the current approach of Parts 1, 2 and 3. What are your views on this?

Respondents were invited to select one of the following options for each vision: Strongly agree, Agree, Neither agree nor disagree, Disagree or Strongly disagree. Respondents were also invited to write a response into an open text box.

Question 13: We believe that the best way to describe the competencies architects need may be to describe what an architect must KNOW, what they must be able to DO, and how they must BEHAVE. To what extent do you agree?

Respondents were invited to select one of the following options for each vision: Strongly agree, Agree, Neither agree nor disagree, Disagree or Strongly disagree. Respondents were also invited to write a response into an open text box.

Question 14: Are there any other views you would like to share with us about this work?

Respondents were invited to write a response into an open text box.

• We received 711 unique responses to the survey from different groups, including architects, students, educators, and other built environment professionals.
   
• Each of the five aspects of ARB’s vision for success received high levels of support. The most popular was the need to provide future architects with skills, knowledge, experience, and behaviours that they can develop and apply throughout their careers (which was supported by 92% of respondents).
   
• Our proposal to move from a rules-based approach of the current Criteria to an outcomes-based approach was supported by 80% of respondents.
   
• Our suggestion that the structure of education and training needs to change from the current approach of Parts 1,2 and 3 was supported by 65% of respondents. Architecture students were most likely to agree with the need for change (94%) followed by related professionals working in the built environment (90%) and over half (55%) of architects.
   
• One of the most popular suggestions made by respondents was that ARB should restructure the requirement for professional practical experience. Respondents also raised the need for more flexible ways of learning and training, and suggested we find ways to reduce the cost and time it takes to qualify.
   
• Respondents also raised areas of architects’ competence that should be considered as part of our review. The most common were business skills (including skills such as time management, professional competence, and general preparedness for working in a practice); professionalism and ethics; climate change and sustainability; and health and safety.
   
• Some respondents also raised concerns about working conditions and mistreatment, and that the current system disproportionately affects or counts against women, transgender or non-binary people, people from a minority ethnic group, or people from a lower socio-economic background.

We produced an analysis report of the survey and this is available here: arb.org.uk/wp-content/uploads/ARB-Education-Survey-Report-June-2022.pdf 

• The insights gained through this survey are invaluable in informing how we will work with the sector to modernise initial education and training. We will continue to develop the outcomes-based approach as well as more specific proposals on how we can reform the current regulatory requirements around the current three-part structure to enable more innovation, flexibility and support diversity.
   
• The ideas and suggestions in our report are derived from survey respondents and are not final proposals from ARB. Structural change will take time, and we intend to develop our proposals through extensive two-way engagement with institutions, architects, and other relevant organisations through further meetings and workshops. Once we have proposals for a new structure, we will run a public consultation on both the proposed structure and its phased implementation, so that all interested stakeholders have the opportunity to help shape it.
   
• We are also considering other work we can do to address the points raised by respondents. It was concerning to read the worries raised about mistreatment, particularly towards those just beginning their careers. We will bear in mind the examples raised by respondents, recognising that while we don’t regulate businesses, architects do have responsibility for the control and management of practices. These issues will be included the forthcoming review of the Architects Code of Conduct and Practice; this provides us with another opportunity to consider how we articulate the requirements for fair and professional behaviour towards communities, clients, and all colleagues including employees.

• The Building Safety Bill will give ARB new powers to monitor the training and development architects carry out throughout their careers. We’ll use this to implement a CPD scheme that will encourage architects to maintain and develop their competence to practise.
• ARB invited views on the proposed principles to underpin that scheme.
• The survey comprised of six questions.
• Two were ‘closed’ multiple-choice questions, with the remaining four using an ‘open’ free-text element where respondents could give more insight into their views. The questions are reproduced in order below:

Question 10: To what extent do you support each of the four proposed principles for our CPD scheme?

1. Improve the overall competence of the profession
2. Tailored by architects to their own practice and needs
3. Proportionate and deliverable
4. Avoid duplication where possible

Respondents were invited to select one of the following options for each principle: Strongly support, Support, Neither support nor oppose, Oppose or Strongly oppose.

Question 11: Are there any key points missing from the principles?

Question 12: What type of learning and development (this could include formal or informal) have you found most useful in your practice?

1. Self-directed reading
2. On the job learning
3. Training delivered by an external provider
4. Other type of learning and development

Respondents were invited to select one of the following options for each type: Very useful, Somewhat useful, Not so useful, Not applicable

For ‘other’, they were invited to write a response into an open text box.

Question 13: Please tell us about any barriers you have observed that have prevented you or architects you know from undertaking good quality CPD?

Question 14: Do you have any examples of particularly good or innovative CPD?

Question 15: Is there anything further you would like us to bear in mind as we develop the monitoring scheme?

• We received 763 unique responses to the survey, drawing from across the profession with responses from different sized practices and architects at various stages in their careers.
• Each of ARB’s proposed principles received high levels of support. The most popular of the four principles was supported by 91% of respondents, and the least popular was still supported by a majority 81% of respondents.
• There was strong support for informal learning and development, reflected also in high levels of support for ARB’s principle that architects should be able to tailor CPD to their practice, and the principle that the scheme should be proportionate.
• Roughly one in ten architect respondents expressed the view that they would appreciate and benefit from flexibility to decide when they undertake and record CPD.
• Responses made it evident that not all architects are able to access all types of CPD equally.
• Two thirds of respondents raised concerns about accessing good quality CPD.
• One third of respondents raised (unprompted) the topic of how CPD should be recorded or monitored, often with a rationale for reducing the administrative burden for architects complying with the new scheme.

We produced an analysis report of the survey, which has been discussed and approved by our Board. This report is available here: 

• We intend to create a scheme that offers flexibility and will avoid creating restrictions about the type of learning and development architects undertake.
• The feedback from respondents about potential barriers to undertaking CPD demonstrates alignment with ARB’s principle that the scheme should, where possible, avoid placing any additional financial costs on architects.
• Any desire for flexibility will need to align with the logistical requirements of monitoring compliance with the scheme, which is likely to run on an annual basis for efficiency.
• We will engage with other professional bodies that run CPD schemes to investigate whether it would be possible to allow architects to record CPD activities in one place that ARB can access and monitor, providing that record complies with ARB’s scheme requirements.
• We will develop detailed proposals for the scheme and publicly consult on it prior to introducing it, which will be in 2023 at the earliest.