I was pleasantly surprised to find that I had authored one of the first letters of the year in the Architects’ Journal. This is especially surprising as I didn’t actually submit any letter to the AJ – rather, only commented on an online article discussing protection of architectural function. Apparently it was relevant enough to warrant a (more elegantly) paraphrased summary in the written AJ last month (Vol. 253 Issue 01, 29.01.26).
The letter critiques a reform to architectural regulation mooted by MHCLG, which would see some form of protection of ‘architectural function’. The ARB has also confirmed ‘very detailed’ discussions with MHCLG about this idea. There is a lack of further detail from MHCLG or the ARB about what exactly this might entail, (or, indeed, exactly why this is necessary) and in the absence of detail, there has been much speculation online.
The general idea seems to be that non-architects could be excluded from submitting building control and planning applications. This, to me, seems entirely unreasonable, and would likely put several smaller firms out of business. It would disproportionately affect smaller businesses and immigrant architectural professionals, while larger firms and British-qualified architects would be entirely unaffected. At a time when the ARB is seeking to widen access to the architectural profession, this would be entirely counterproductive.
I am myself an ‘architectural designer’, not formally registered as an architect, yet carrying out architectural functions which are within my competence. I began my career in conservation, subsequently started a placement at an architectural practice during COVID, and learned architecture ‘on the job’, eventually rising to a senior post. I set up my own small, solo practice at the end of 2024.
I have considered and attempted to formally qualify as an architect, but until quite recently the qualification process was so convoluted as to be entirely unworkable. It would have required ‘restarting’ education at undergraduate level, studying full-time for four years, then studying two further masters-level qualifications. My previous experience and knowledge would have been irrelevant, and I would have been forced to effectively abandon or substantially reduce my professional work, while getting into considerable student debt. For the price of simply being called an ‘architect’, this seemed rather pointless, and given the finances, indeed, impossible.
Added to this, my experience of the skillsets of recent graduates made it quite doubtful whether the seven years of education would actually lead to any tangible, intellectual or practical benefit to my architectural work. Grads generally seemed to be fairly clueless as to how to do even the most basic of architectural tasks. This was reinforced by my brief attempt at a Part I course, taught entirely by non-architects, preaching in grandiose terms about ‘how architects think’ without actually having any experience of architecture practice in the UK themselves. The whole affair seemed quite Kafkaesque and, in short, a total waste of time and money.
Similarly, those with equivalent qualifications in other countries (even within the EU, where standards can be more stringent) cannot readily qualify as architects in the UK. They may be registered as architects in their home countries, but for obscure bureaucratic reasons, their Part I or Part II may not be formally ‘recognised’ by the ARB. These individuals may be carrying out the work of an architect, with several years practicing as such, but to qualify as an architect they would need to ‘restart’ their education at undergraduate or postgraduate level. This, clearly, is absurd.
The one saving grace of this wholly Kafkaesque registration system is that it can (just about) be sidestepped. Unregistered architects can do everything an architect does – so long as they are prepared not to actually call themselves an ‘architect’ in the UK.
The ARB has been consulting on reforms and partially implemented reforms which remove the requirement for a Part 1 undergraduate degree. This is quite welcomed and, incidentally, acknowledges just how pointless the Part I degree is in educating architects in the real-world practice of architecture. Soon, architects will only need a Part II and III to qualify, substantially reducing the bureaucratic and financial overhead to registering.
These reforms have been carried out in the name of widening access to the profession, a long term aim of the ARB. So it is somewhat surprising that now, the ARB is (apparently) exploring the opposite approach and making it more difficult to practice in architecture for those with unconventional backgrounds. Granted, this will not affect registered ‘architects’ whatsoever, but for those who cannot afford to go back to university, it may push them entirely out of the profession.
Protection of function – improving building safety?
It seems this idea has arisen principally from the Grenfell disaster and the subsequent fallout concerning building safety matters and wider regulation of the construction industry. Presumably it is thought that excluding non-architects from submitting these applications is a necessary step to ensure building safety.
However, for medium to large scale developments such as Grenfell, there would be no effect as such projects are already carried out by large architectural firms, where PI insurance would require submissions to be made by a registered architect. These reforms, therefore, would only affect small scale development, such as home extensions, new-build homes, or minor commercial work (signage, shopfits, etc). Such applications are routinely carried out by a range of professionals and indeed sometimes by applicants themselves.
In these cases, it is not clear how building safety would be improved by excluding non-architects from submitting building control and especially planning applications. The purpose of the planning system at a domestic scale is not to ensure building safety, but to assess whether an application is in conformity with the development plan. Building safety is not a material consideration for such projects, and even if it were made to be, planners are in no position to judge these matters. Similarly, small-scale building work can proceed with the issuing of a building notice, which does not require any building control drawings whatsoever.
For these projects, the managerial role of an architect or designer is also much reduced, with many projects managed mostly or even entirely by the builder and/or client, rather than any individual fulfilling the traditional role of an ‘architect’ from start to end. In these cases, the builder carries the primary responsibility to ensure building safety, both during and following construction. And yet, there seems to be no discussion about regulating the title of ‘builder’, never mind protecting the function of ‘building activities’, despite this profession being far more critical and ubiquitous in ensuring building safety at all scales and stages of construction.
The fact that the ‘architectural function’ is only incidental to the delivery of smaller projects is perhaps why clients often reasonably opt to use easier or cheaper options to prepare drawings at building control and particularly planning stage. The expense of a fully registered architect is simply not necessary for this sort of work. It indeed seems quite oppressive for clients to be forced to use an architect when building, for example, a shed or refurbishing a bathroom.
Protection of function – protecting the public interest?
Commentary online points to non-architects undermining confidence in the profession by carrying out poor work, perhaps fraudulently posing as a registered architect, and generally leaving clients ‘high and dry’ when their projects fail at planning or construction stage, only for a ‘proper’ architect to clean up the mess. It is implied that the standard of work produced by registered architects is far superior to that of architectural designers or other consultants. Protection of function is therefore necessary to protect the public from these ‘scammers’.
I have served on the Bloomsbury CAAC since 2019, and as chair since 2024, where we assess approximately 700 planning applications every year in some of the most highly developed and populated areas in the country (Bloomsbury, King’s Cross, Holborn, Covent Garden, and Fitzrovia). One would expect the quality of submissions to be of a reasonably high standard. Far from it, however – at least on the domestic scale, and sometimes even on a larger scale, submissions are routinely confused, contradictory, often incorrect and generally quite incompetent. Except in the case of major developments, where established architectural firms are behind the schemes, there is really no difference in the quality of submission between non-architects and registered architects. Indeed, I have been so shocked by the quality of architects’ submissions on occasion that I’ve had to check the ARB register to confirm that the firm/individual is indeed registered.
In short, incompetence in the architectural profession is evident on both sides of the regulatory divide. The title of architect is, by no means whatsoever, an assurance of quality.
Concluding remarks
Much of this discussion is somewhat circumstantial and doesn’t ‘prove’ anything, but, nevertheless, it does call into question whether protecting architectural function would actually achieve anything in practical terms. Any benefits to building safety or confidence in the profession would admittedly be quite slim.
On the other hand, the harm that would be caused to architectural professionals, particularly from unconventional backgrounds and those who qualified abroad would be quite severe. Small businesses and sole practitioners focusing on domestic-scale projects or with specialisms like conservation, landscape design, or energy efficiency would be particularly affected. Protection of function would, presumably, force such individuals back into education, regardless of their experience or competence. With such poor availability of apprenticeships and part-time education routes, along with the high costs of university education, this may prove impossible for many. Certainly in my case I would likely leave the profession entirely.
The regulatory regime and the qualification process to become registered are, obviously, intrinsically linked. Should the registration process be reformed to take full account of an individual’s competence and experience, without any arbitrary prejudice against foreign qualifications, protection of function may in fact be quite reasonable. But to place a blanket protection of function on architectural activities without addressing the convoluted and bureaucratic qualification system would simply be unjust and discriminatory.
Our letter in the AJ
There’s little to choose in quality and competence between ARB-registered architects and architectural designers
‘The key difference between regulated professions like medicine and architecture is that much of architecture is creative and creativity cannot and should not be regulated.
‘I agree that the technical and ethical aspects of architecture should be regulated, but the current system does not achieve this whatsoever, sadly. And in my long experience of assessing planning applications in Central London, there is really little difference in quality and competence between registered architects and architectural designers. I have often been so shocked by the designs of architects I have needed to check the register to indeed confirm they are registered.
‘It’s a very complex topic that needs addressing, but any short-term ‘fixes’ like a blanket protection of function, without addressing wider issues in architectural education and regulation, will only make the situation worse and unfairly discriminate against skilled and, particularly, immigrant architectural professionals.’