LICENSURE MATTERS 3 / Reflecting On The US-UK Mutual Recognition Agreement (MRA)
Fiona Mckay
Ten years ago, a collaboration between NCARB and ARB on architectural reciprocity would not have seemed possible. Not only did the UK’s membership in the EU precluded any professional agreements with the US – qualifications, and in some cases education, were not directly recognized by either country. At the time, the UK was nowhere near Brexit, and many people had to go through a process of repeating courses, paying exuberant fees, and submitting loads of paperwork while navigating an obscure and complicated system. The barriers to enter the profession in the UK from the US, and vice versa, seemed insurmountable.
How times have changed since then: it only took a national referendum, several prime ministers, and a global pandemic to reach a moment of clarity. When news broke of the new Mutual Recognition Agreement (MRA) in June 2022, it felt like a moment of absolution to many US-UK architects – though bittersweet for those that had to go through the hurdles. The significance of this agreement to US architects based in the UK, and indeed, the AIA United Kingdom as a chapter, cannot be overstated. While Mutual Recognition may not be as meaningful to those already established in practice, the forecast is heightened activity for the AIA UK Emerging Professionals committee and – we hope – a renewed appreciation for the AIA UK chapter from both the AIA and RIBA motherships.
A Comparison of US & UK Paths to Qualification
Licensure in the US is administered by NCARB (National Council of Registration Boards) and its national counterpart in the UK is the ARB (Architects Registration Board). Unlike the ARB, NCARB does not award licenses or keep a register of qualified architects; this is in fact handled by individual states or territories. Instead, NCARB handles the certification process which allows candidates to submit applications for license within individual jurisdiction. The NCARB Certificate can therefore be considered as a “passport” to practice in individual states. Some states only require the NCARB Certificate to register; others have additional requirements, which can be thought of as a “visa.” The California Supplemental Examination (CSE) is one such example.
To achieve an NCARB Certificate, candidates on the standard path must first complete an NAAB-accredited B.Arch. or M.Arch. degree program. The B.Arch. program lasts 5 years; M.Arch. programs can vary in length depending on previous education but can be up to 3 years and require an undergraduate degree. In addition to education, candidates are required to complete examination and experience criteria. These are the six Divisions of the Architect Registration Examination (ARE) (a standardized test) and 3,740 hours of practice hours across six experience areas under the supervision of a professional mentor. This practice component is known as the Architect Experience Program (AXP).
In the UK, the ARB takes on the same role as NCARB and additionally functions as a state or territory. Unlike NCARB, the ARB does award licenses and keeps a register of qualified architects. It also handles the education and experience components through the Criteria for the Prescription of Qualifications Parts I, II, & III. Part I relates to the first three years of university education, followed by two years of education for Part II (a diploma or a Master’s degree). Parts I and II are often bundled into the same degree program. In the UK, there is a practice of assigning individuals who have not completed Part III the title of a “Part I -” or “Part II Architectural Assistant,” regardless of educational background or professional credentials.
Once the Part I/II educational criteria are complete, the final Part III fulfils the examination and experience requirement. The experience component consists of 24 months in architecture practice while completing a Part III accredited course. Unlike the ARE sit-down test, the ARB Part III examination component is an assessment process involving a professional review, preparation of case studies, a written examination, and an interview. The Part III examination is perhaps more comparable to NCARB’s AXP program than the ARE, whereby the qualified architect supervisor fills a similar role to the Part III examiner. At present, there is no standardized test requirement for architects to enter the ARB register.
How would you describe the process of qualification in the UK / US?
How do you think the MRA will be useful for UK / US students and architects?
UK Registration as a non-UK Architect
The current method for registering as a UK architect without the ARB-accredited Parts I/II is through an “Alternative Route to Registration,” specifically the ARB Prescribed Examination. This is the process AIA members have used in the past to qualify in the UK in absence of an MRA agreement, but it can be quite demanding. Like the standard Part III examination, it requires interviews and portfolio work to demonstrate equivalency. The problem is that these applications are expensive and can be rejected. It is therefore vital that candidates take extra care and seek sound advice in preparation. Experience in the UK is likely advantageous in understanding how to demonstrate the necessary competency. If the Prescribed Examination is successful, the candidate would then be required to complete the Part III to join the UK register.
UK Registration as a US Architect (MRA)
If the ARB accepts the non-UK education or experience – waiving any one of the Parts I or II requirements – this likely will not allow the individual to take advantage of MRA agreements. This would be because the candidate obtained a UK license via an "alternative route" (non-UK education); subsequently, if that same candidate wished to register in the US, likely they cannot use the UK qualification to obtain an NCARB Certificate.
Currently, only the “standard route” is allowed on either side of the US/UK MRA. This measure excludes non-UK and non-US architects from taking advantage of reciprocity via a US or UK license. For this reason, it is also not permitted to qualify in the UK via another MRA; for example, a Mexican architect qualified in the US via the US/Mexico MRA cannot use the US certification to qualify in the UK through the US/UK MRA. Such arrangements are not possible at this time. Nonetheless, the ARB has expressed a wish to investigate such options in the future.
The implementation of the new US-UK MRA will transform the process for US architects to register in the UK, and vice versa. For US architects, the NCARB Certificate – and a supplementary test – would be the only requirement. (This measure is intended to entirely replace the prior Prescribed Examination requirement for NCARB Certificate holders.) This remains to be confirmed as more information becomes available. At the time of writing, the ARB is still waiting on the UK Parliament to complete its legislative process to complete the Agreement. The estimated date is early 2023.
A diagram of the Alternative Routes to Registration in the UK with architectural education that is not recognised. Foreign architectural qualifications, other than Irish, are not currently recognised. However the ARB is currently working on MRA agreements with other countries that will circumvent this restriction, so opportunities will likely improve in the future following Brexit. For more information, please consult the ARB website. Image source: ARB Website, click HERE to view
US Registration as a non-US Architect
Unlike the UK, the US consists of multiple licensing boards that are managed by individual states. NCARB operates on a national level to standardise and manage most requirements set forth by the individual boards, but not all of them. Therefore, registering as an architect in any US jurisdiction will typically be facilitated by an NCARB Certificate obtained through the “Foreign Architect Path.”
Non-US qualified architects have the option to pursue an NCARB Certificate by verifying the qualification and completing the two education and experience components: the Architectural Experience Program (AXP) and the Architect Registration Examination (ARE). Alternatively, non-US candidates without a NAAB-accredited education have the option to request an educational assessment through a program called Education Evaluation Services for Architects (EESA). The EESA evaluation is administered by the NAAB organisation and compares academic transcript(s) to the NCARB Education Standard. The process will determine the education meets the standards for (a) initial licensure in a jurisdiction, (b) NCARB Certification, or (c) reciprocal licensure between jurisdictions. The evaluation will also identify whether any additional education is required.
Once the non-US candidate obtains an NCARB Certificate, this may only be used to apply for an initial license in a U.S. jurisdiction that accepts an NCARB Certificate issued through the Foreign Architect Path. The NCARB Certificate may allow additional registrations in US jurisdictions more easily; however, it is necessary to check the requirements of the individual jurisdictions to ascertain whether the specific case allows for this.
A diagram of the Foreign Architect Path to licensure in the US with either an architectural license or architectural education that is not recognised by the respective US organisations responsible for certifying. Though full of hurdles, the Foreign Architect Path is not impossible and will likely improve in the future. For more information, please consult the NCARB website. Source: NCARB Website, click HERE to view
US Registration as a UK Architect (MRA)
The implementation of the new US-UK MRA will transform the process for US architects to register in the UK, and vice versa. For UK architects, it is likely that the ARB qualification will earn an NCARB Certificate directly with no other requirements; however, this remains to be confirmed as more information becomes available. It is important to note that like the “Foreign Architect Path”, an NCARB Certificate obtained through the US-UK MRA may not be accepted in all US jurisdictions. It will therefore again be necessary to check the specific requirements of each jurisdiction before deciding where to apply for an initial US license.
This article is a continuation of the 2022 LICENSURE MATTERS series. This is an ongoing story; please refer to NCARB and ARB for the latest information.
Written by Adelina Koleva, AIA
