The regulator steps into the spotlight

It is difficult to talk about the future of architecture without also talking about regulation. In the years since Grenfell, the architectural profession has been forced to reckon with its own failings and its role within the systemic shortcomings across construction that contributed to the tragedy.

Into this unsettled territory has stepped Hugh Simpson, a former health sector regulator with no background in the built environment but a deep understanding of what happens when regulation fails.

Since joining the Architects Registration Board (ARB) as chief executive in 2020, Simpson has set about rethinking what it means to regulate for the public good. Under his leadership, ARB has pushed through major reforms to architectural education, introduced mandatory continuing professional development (CPD), and negotiated a series of mutual recognition agreements (MRAs) with architectural bodies around the world.

Where once it was seen as a cautious registrar of titles – and occasional irritant – ARB is now taking on something closer to the role of an “activist regulator”, a description with which Simpson is emphatically happy.

BD meets him in ARB’s new offices at 70 Gray’s Inn Road. Previously based on Weymouth Street since its foundation, the move appears to mark a long overdue shift away from the immediate orbit of RIBA’s Portland Place headquarters.

“There is a line in our corporate strategy,” Simpson explains, “which says we want to show and demonstrate leadership on some of the key issues. It’s quite easy to keep your head down as a regulatory body and not address some of those things.

“If you are not willing to make some difficult decisions, if you are willing to avoid risk, then you won’t do anything, and I think that lets the profession down – and it certainly lets the public down.”

From Shipman to Grenfell

Simpson’s background is in public policy and communications, with stints as head of public affairs at the General Medical Council, and director of strategy at the General Pharmaceutical Council. It was at the GMC, in the aftermath of the Harold Shipman scandal, that he first became immersed in the world of professional regulation.

“I kind of got hooked at that point,” he says of “that interface between regulation, professional standards and big public policy challenges.” It was here that Simpson saw the limits of self-regulation and the consequences when those limits are ignored.

The Shipman inquiry, led by Dame Janet Smith, explicitly criticised the GMC’s handling of fitness-to-practise issues and called for more patient-centred regulation. The inquiry said the GMC was “an organisation designed to look after the interests of doctors, not patients”, and recommended reforms to make it more focused on public protection.

When he joined ARB, Simpson felt that the parallels with his earlier work were striking. “I did a lot of reading around Grenfell,” he says. “And although the technical stuff was hugely different, some of those fundamental things felt quite similar.”

“A lot of it is to do with failures in the way in which regulation happens,” he adds. “Failures in leadership, but fundamentally failures in culture.”

Too much regulation?

Amid ongoing political scepticism about regulation – despite, or perhaps because of, the deregulatory climate that contributed to the Grenfell tragedy – including recent criticism of quangos by Keir Starmer, Simpson is keen to distinguish between general regulatory bureaucracy and professional regulation. The regulation of architects, he argues, exists for a simple reason: the work of architects carries a potential risk to the public.

“Self-regulation was seen as not compatible with the broader public interest,” he explains, in relation to the reason why architects and other professions have either adopted or had independent regulators imposed on them. “Too many conflicts of interest.”

In that context, Simpson’s approach is not about defending professional titles. It is about ensuring that public confidence is earned and maintained.

“Our job is pretty simple,” he says. “How do you get people on the register, how do you keep them on, and how do you take them off? Separating competence from incompetence, I suppose, is another way [of putting it].”

Not all architects are persuaded. Some view the steep rise in the ARB’s retention fee as evidence of a regulator overreaching its remit. The fee increased by 72% between 2021 and 2025, from £119 to £205. Critics point to the board’s legal spend, which rose from £982,254 in 2019 to £1,532,957 in 2023, and argue that architects are being forced to bankroll reforms they neither chose nor fully support.

Education reform

One of the most consequential changes under Simpson’s tenure has been the overhaul of the architectural education framework. In place of the longstanding Part 1, 2 and 3 model, the ARB is introducing a simpler structure centred on competence rather than educational inputs or equivalence.

“We felt that the historical model, which meant you could have Part 2 and Part 3 and 20 years’ work experience, but were deemed as not competent [if you lacked a Part 1 undergraduate degree], seemed really anachronistic,” Simpson explains.

The old model, introduced in the 1950s and preserved with minimal revision since then, offered little flexibility and excluded many would-be architects who had taken alternative routes or studied in other systems.

By removing the requirement for a prescribed undergraduate degree in architecture, the reforms open the door to a more diverse pool of candidates, including those with non-cognate degrees and mid-career changers. It also makes it easier for international applicants who would previously have been forced to duplicate their studies or go through a drawn out and expensive process of proving equivalence.

For a profession struggling with diversity, high drop-out rates and barriers to entry, the reforms offer the possibility of long-overdue change. The challenge to schools is to provide new courses, with competency to be assessed at a single point.

Simpson is clear that ARB will not prescribe a specific model. “Regulators get into trouble when they prescribe a particular route,” he notes. “We want to encourage innovation.”

There has been strong interest from providers. “We’ve had almost a dozen new courses apply,” says Simpson.

The reforms are not without critics. Some fear they risk diluting standards. But for Simpson, the goal is not to abandon rigour, but to redefine it.

“It felt too much that we focused on how to keep poor or underqualified people off the register, rather than thinking how do we get good and competent architects on the register,” he says.

Course approval and the RIBA

Changes have not always gone smoothly. One of the biggest points of friction has been the duplication of effort between ARB and the RIBA in course accreditation and oversight. The RIBA has long raised concerns about what it sees as bureaucratic overlap, with some institutions also questioning the need for two sets of visits.

Simpson acknowledges that mistakes were made, and that ARB could have communicated more clearly with schools: “We did not communicate well around the introduction of charges for accreditation. We were surprised that it took them by surprise. But that’s on us.”

Yet, while Simpson maintains a collaborative tone, the implication is clear: ARB’s duty is to the public interest, whether or not professional consensus follows.

Practical experience and culture change

If architectural education has been modernised on paper, the professional practical experience (PPE) component remains a stubbornly unresolved problem. For decades, students have struggled to gain the necessary exposure to real projects, with some employers withholding key experiences as a form of gatekeeping. In response, ARB established the PPE commission, chaired by Chris Husbands, to look at how regulation could support meaningful change.

The commission’s work focused on three areas: the creation of a national record of competence; a shift in responsibility for oversight from students to higher education institutions; and a culture change around mentoring and power.

Simpson is clear about the power imbalance, emphasising how in the current model students are responsible for finding, coordinating and recording their practical experience, even when practices do not always deliver what is needed. As the commission concluded, it is unreasonable to expect those with the least influence to bear the greatest burden.

ARB intends to develop a national record of competence to replace the existing professional experience and development record. It will also provide clearer guidance to institutions, encouraging them to integrate practice-based learning into formal education and to take a lead role in coordinating the experience students gain.

The most challenging part, however, may again be cultural. Simpson acknowledges that there are already practices doing this well, but says it is time to expect more from the rest.

“We need to encourage and spread the sorts of things that are good,” he says. “The commission’s got some really good examples in its report. I think people should look at them.”

Low pay, low fees and ARB’s limits

One of the most intractable problems in the profession is not within ARB’s remit. Fees and consequently pay are generally poor.

Many practices, especially smaller ones, say they cannot afford to train students properly. Simpson understands the difficulty but he does not accept that this should halt reform.

“One thing the reforms cannot do is address some of the structural financial challenges within the sector,” he says. “But to say it is too tough for practice, so we will just let students suffer, would have been fundamentally wrong.”

Simpson describes the funding environment as “really difficult”, especially for smaller firms and also for universities. “It is tougher for smaller practices,” he says. “But that cannot be a reason to avoid reform.”

The emphasis is instead on designing a system which works within those constraints, not by lowering standards, but by opening up new, more flexible pathways. That includes by allowing more training to happen in the workplace.

Apprenticeships and funding threats

For Simpson, Level 7 apprenticeships have exemplified positive change. They integrate learning with live project experience and widen access for students who might otherwise be excluded from the profession. The model aligns with ARB’s shift towards outcome-based education, allowing students to “earn while they learn” and directly linking learning outcomes with professional behaviours.

“Apprenticeships have demonstrated many of the things we really want to see,” he says. “High-quality integration of theory and practice.”

But the government’s recent decision to withdraw funding for most Level 7 apprenticeships for over-21s from January 2026 is a major setback – a move likely to render the route unviable for many would-be architects.

For ARB, the withdrawal of funding is not just a policy reversal; it is a significant blow to efforts to reform architectural education and open up the profession to those from non-traditional or disadvantaged backgrounds.

Mandatory CPD and regulatory maturity

Another major intervention under Simpson’s leadership has been the introduction of compulsory CPD. For the first time, architects must now carry out CPD each year and provide a reflective statement as a condition of remaining on the register. But what might appear a straightforward requirement has, again, proved culturally challenging.

“We probably underestimated how big a culture change this is,” Simpson reflects. While many professionals already undertake informal learning, formalising that into a system of self-reflection and accountability has required a shift in thinking.

ARB has focused its approach on outcomes rather than hours. Yet the shift has not always landed as intended. “No matter how many times we explain it, people still come back and say, ‘How many hours do I need to do?’” he says. “That is not what we are asking.”

The CPD scheme is emblematic of ARB’s maturing regulatory stance. It is part of a broader movement away from inputs and equivalence towards behaviours, competence and public trust. The aim is not to simply create new rules, but to support a culture of lifelong learning.

For Simpson, it is also about aligning architecture with other regulated professions. “Most regulators already do this,” he says. “We are just catching up.”

Global agreements and registration reform

ARB’s post-Brexit strategy has been to simplify registration for overseas architects while opening up new global pathways for UK-registered professionals. Under Simpson’s leadership, the regulator has concluded new MRAs with Australia, Hong Kong, New Zealand, the US and most recently Canada, designed to smooth entry to the register for professionals from jurisdictions with broadly comparable standards.

In contrast to the mutual recognition that once existed between the UK and EU member states, these agreements do not automatically confer registration or the right to work in those countries.

An agreement with the EU remains under discussion, though negotiations are now managed through the terms of the UK-EU trade deal. “It is more stuck in politics,” he admits. “We have presented our recommendations, so we are waiting for government and the European Commission to move forward.”

Reservation of function: ‘a live debate’

A growing area of debate within the profession is the potential for what Simpson prefers to call “reservation of function.”

“I prefer the term reservation of function to protection of function, because protection feels too much about protecting the profession,” he says. “The question should be: to what extent would the public benefit if only architects or certain professions carried out these functions?”

The role of principal designer under the Building Safety Act is seen as one area where reservation of function is already emerging. But Simpson is clear that this debate must be led by the profession itself, not imposed by the regulator. “There is a live debate,” he says. “The government has opened the door to thinking about it, particularly post-Grenfell.”

As the system adapts to the Building Safety Act, the profession must decide whether it is willing to define and take ownership of its role. As Jack Pringle has observed, the principal designer role is “not a hindrance, but a great opportunity for architects to demonstrate collective commitment to a safer built environment, and to lead the way”.

EDI and the revised code

Recent ARB research suggested high levels of discrimination against women and ethnic minorities in the workplace. ARB’s recently published EDI strategy for 2025 to 2027 marks a significant expansion of its ambitions around inclusion, access and professional culture.

The strategy outlines four goals: improving access to the register, becoming a more inclusive organisation, supporting better workplace cultures and tackling discrimination and harassment. Some of these lie within ARB’s direct remit, while others will rely on collaboration with institutions and professional bodies.

As ARB chair Alan Kershaw puts it: “This strategy is a bold step toward building a profession that truly reflects the diversity of our society, and a profession where talent and ability, not background or circumstance, determine success.”

The new strategy builds on changes already underway at ARB, including the revised Architects Code, which signals a shift in regulatory emphasis from rule enforcement to cultural leadership. As Simpson explains, “EDI is not an adjunct, it is pretty much core to delivery of high quality.”

The updated architects’ code reflects this, with clearer expectations around workplace culture and public interest. “Poor culture, poor psychological safety leads to high-profile failure,” he says.

Still, ARB is not attempting to act as an employment tribunal. “We are not trying to replicate employment law,” Simpson says, “but if there is evidence of poor practice, we will shine a light on it.” The aim, he says, is not to catch people out but to promote a shared understanding of what responsible practice looks like.

RIBA and the limits of alignment

For all the reforms that ARB has introduced, its relationship with the RIBA remains a careful balancing act. Operationally, the two organisations collaborate well, for example on the delivery of CPD. But at a strategic level, there are natural points of tension.

ARB is an independent regulator with a public protection mandate; RIBA is a membership body tasked with advancing the art and science of architecture. That difference in focus matters, and influences the relationship. “If there were no tensions,” Simpson says, “we probably wouldn’t be doing our job.”

He is careful not to characterise the relationship as adversarial: “We meet regularly with RIBA’s executive team. I think we’re able to share areas of disagreement privately, and that’s healthy.”

A profession at the crossroads

After five years at the helm of ARB, Simpson remains clear about what regulation can achieve and where he believes its remit ends. Under his leadership, ARB has repositioned itself as a modern, independent regulator focused on outcomes, competence and public interest. But he is clear that reform within ARB will not be enough on its own to address the major challenges facing architects.

“The future of the profession is a matter for the profession,” he says. “But where it ends up will have a direct impact on what we do.”

For Simpson, this means being open to new responsibilities and new ways of working, but also honest about where reforms have not landed well. “We want to be self-confident enough to say where reforms have not gone well and adapt.”

Some conversations are still to come. “Some of the debates we expected have not yet happened, like specialisation or post-registration standards.” The moment for them may arrive very soon.