State boards and NCARB

The second week begins with a guest. Margaret Olafson is a retired architect who served for six years as a licensed member of a state licensing board in the region, and she comes to the Eberle Moss conference room with a folder of anonymized cases. She tells the students that most architects meet their licensing board only three times in a career: when they apply for a license, when they renew it every two years, and when they take continuing education. A few meet it a fourth time, when someone complains. Her aim this week is to make the board and the national council familiar, so that the students understand what they do, why they ask for what they ask, and how to stay on the right side of them.

What a state board does

Minnesota's AELSLAGID board exists because the state's statutes create it. Its job is to protect the public by making sure that people who practice the regulated design professions are qualified and practice competently and ethically. To do that it does six main things. It licenses architects who meet the education, experience and examination requirements, and it grants licenses by comity to architects already licensed in other states. It renews licenses every two years and checks that architects have completed the required continuing education. It sets rules of professional conduct, including rules about sealing drawings and about conflicts of interest. It registers firms that offer services in the regulated professions. It investigates complaints and disciplines licensees. And it acts against people who practice or use a protected title without a license.

The board is appointed by the governor and includes licensed members from each of the professions it regulates, along with public members who are not licensed. It meets regularly to decide on applications, rules and disciplinary cases, and it has an executive director and staff who handle the daily work. Like most state boards it relies heavily on the National Council of Architectural Registration Boards for the parts of licensure that are the same everywhere: the experience program, the examination and the records that architects carry from state to state. Olafson says that board service is unpaid or nearly so, and that the licensed members give many hours a year to read applications and complaints and to sit in hearings, which is the part of regulation the public rarely sees.

Licensing and the two-year renewal

To be licensed in Minnesota, an applicant normally needs a professional degree from a program accredited by the National Architectural Accrediting Board, completion of NCARB's Architectural Experience Program, and passing scores on all divisions of the Architect Registration Examination. The next lesson explains each of these. Once licensed, an architect renews every two years. The renewal requires 24 professional development hours earned in the two years before the renewal, of which at least 2 hours must be in professional ethics; a professional development hour must last at least fifty minutes, up to 12 general hours may carry over from the previous period, and ethics hours may not carry over. The board does not pre-approve courses, so the architect must keep records for four years in case of an audit.

Continuing education is the part of regulation that architects notice most often after they are licensed. The idea is simple: building codes, materials, technology and law change, and an architect who stopped learning on the day of licensure would soon be practicing with out-of-date knowledge. The requirement is also a modest one, and Olafson admits that it can be met carelessly by sitting through lunchtime presentations from product manufacturers. She urges the students to plan their learning instead, choosing courses that close real gaps: code changes, accessibility, building science, contracts and the business of practice. A well-planned record of continuing education is also a defense if a complaint ever questions an architect's competence.

# Minnesota renewal check: 24 hours in the period, at least 2 in professional ethics,
# up to 12 general hours carried over from the last period (ethics may not carry over).
log = [
    ("2024-09-10", "code update seminar", "general", 3.0),
    ("2025-02-03", "manufacturer talk on windows", "general", 1.0),
    ("2025-03-20", "contracts and risk workshop", "general", 6.0),
    ("2025-05-08", "accessibility standards course", "general", 4.0),
    ("2026-01-15", "professional ethics webinar", "ethics", 2.0),
]
carryover = 5.0
general = sum(h for _, _, k, h in log if k == "general") + min(carryover, 12.0)
ethics = sum(h for _, _, k, h in log if k == "ethics")
total = general + ethics
print(f"general hours (with carryover) {general:5.1f}")
print(f"ethics hours                   {ethics:5.1f} of 2.0")
print(f"total                          {total:5.1f} of 24.0")
short = max(0.0, 24.0 - total)
print("status:", "complete" if total >= 24 and ethics >= 2 else f"short by {short:.1f} hours")

general hours (with carryover)  19.0
ethics hours                     2.0 of 2.0
total                           21.0 of 24.0
status: short by 3.0 hours

The Minnesota numbers in the sketch come from the board's published rules for the current period. In the example the architect is short by four hours, which is a common situation a few months before renewal. Eberle Moss keeps a shared log for every architect in the firm, and the office manager checks it each spring so that no one discovers in June that they are short of hours or missing the ethics requirement.

NCARB: the council of boards

NCARB is a nonprofit council whose members are the architectural licensing boards of the fifty states, the District of Columbia and the US territories. It does not license anyone itself. Instead it develops and administers the parts of licensure that the boards have agreed to share: the Architectural Experience Program, the Architect Registration Examination, and the NCARB Record, a verified account of each candidate's education, experience and examination. When an architect finishes, the Record becomes the basis for the NCARB Certificate, which most boards accept as proof of qualification when they grant a license by comity. NCARB also publishes model laws and regulations that states can adopt, and it negotiates mutual recognition agreements with other countries, including the 2014 agreement with the Canadian licensing authorities. Each year it publishes a report called NCARB by the Numbers. The 2025 edition counted 116,005 licensed architects in the 55 jurisdictions and nearly 3,600 new architects in 2024.

Olafson draws a lesson from the national structure. Because the education, experience and examination are largely the same across the country, an architect's qualifications travel with them, and mobility is easier than in many professions. But each jurisdiction still has its own law, its own rules of conduct and its own disciplinary process, and an architect who practices in several places must follow all of them. A complaint in one place can also follow an architect to another, because regulators share information about discipline.

Complaints and discipline

Olafson opens her folder. The cases are real but anonymized, and she reads three. In the first, a homeowner complained that an architect had taken a deposit for a house design, produced a few sketches and then stopped answering calls for four months. There was no written contract. The committee found that the architect had failed to define the services and had not communicated, and it required a reprimand and a course in practice management. In the second, a building official complained that an architect had sealed a set of drawings prepared by an unlicensed designer who worked for another company and whom the architect had never supervised. This is called plan stamping, and it is treated seriously because it defeats the whole purpose of licensing. The architect's registration was suspended. In the third, a contractor complained that an architect had refused to certify a payment. The committee found that the architect had acted correctly under the contract and dismissed the complaint.

The three cases show the range. Some complaints come from clients who feel badly served; some come from officials or other professionals who see a risk to the public; and some come from people who are unhappy with a decision that the architect was entitled to make. The process is designed to tell these apart. A complaint is screened first. If it falls outside the regulator's authority, such as a pure fee dispute that belongs in court, it is closed with an explanation. If it raises a question of competence or conduct, it is investigated, and the architect is asked to respond in writing. Many complaints are resolved at this stage by an undertaking, mediation or a caution. Only the most serious go to a formal hearing, where the regulator must prove its case and the architect may be represented by a lawyer.

Minnesota's board can deny, suspend, revoke or condition a license, reprimand a licensee and impose civil penalties, and its final orders are public. Like most state boards it also has the power to act against unlicensed people, through cease-and-desist orders and penalties. Olafson notes that disciplinary actions are reported to NCARB and shared with other boards, so a suspension in one state can lead to action in another. She adds that the board's rules of conduct, not the AIA's code of ethics, are what the board enforces, although the two often say similar things.

Enforcement against unlicensed practice

Regulators spend a surprising share of their effort on people who are not licensed at all. A designer who advertises 'architectural services' online, a drafting company that prepares permit drawings for buildings above the exemption thresholds, or a builder who calls a staff designer an architect can all be breaking the law. Regulators usually start with a letter, and most people stop when asked. If they do not, the regulator can seek a fine or an injunction. Minnesota's board can issue cease-and-desist orders and seek civil penalties, and repeated violations can lead to court action. Olafson says that architects help by reporting what they see, and that the profession's credibility depends on enforcement being even-handed: an unlicensed designer who does good work on an exempt building is within the law, and the regulator's job is not to protect architects from competition.

Exercise 2: reading the rules

• Find the board's rules of professional conduct and identify the rules on sealing drawings and on conflicts of interest.
• Read the summary of a published disciplinary decision and write a one-paragraph account of what went wrong and how it could have been prevented.
• Make a personal continuing education plan for your first renewal period, naming at least three topics that close real gaps in your knowledge.

Self-check

• Do I know what my regulator does, and what it does not do?
• Can I explain plan stamping and why it is treated so seriously?
• Do I know how renewal and continuing education work where I intend to practice?
• Do I know the first thing to do if I receive a complaint?