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Brexit FAQ’s:  Recognition of UK Qualified Architects in Ireland in the Case of a No-Deal Brexit

Published: Thursday, September 19, 2019

Recognition of UK Qualified Architects in Ireland in the Case of A No-Deal Brexit (1)

Editor’s Note
This guidance document was first published on 08 March 2019, four days prior to the first of a series of three votes in the UK Parliament that commenced on 12 March. The first of the three votes rejected the draft Agreement on the Withdrawal of the UK from the EU. The second vote rejected a no deal Brexit. The third vote instructed the UK government to seek an extension to the Brexit deadline. Although the UK government has now voted to reject a no deal and extend the Brexit deadline the UK could still leave the EU on 29 March 2019 without a deal unless the EU member states unanimously agree to the UK’s request to extend Article 50.

Background
The UK is due to withdraw from the EU on 29 March 2019. On 14 November 2018 the remaining 27 EU Member States and the UK agreed The draft Agreement on the Withdrawal of the UK from the EU. The Agreement provides for a transition period lasting from the withdrawal date up to 31 December 2020. During the proposed transition period the UK would remain a member of the European Economic Area and EU laws would continue to apply to the UK and UK nationals. However the Agreement requires ratification by the UK parliament. If the Agreement is not ratified prior to 29 March 2019 or an extension to the withdrawal date is not granted by the EU, then, the UK will leave the EU without an agreement on 29 March 2019 and EU law will cease to apply to the UK and UK nationals.    

This document provides guidance on how the RIAI proposes to recognise formal qualifications in architecture awarded in the UK and UK nationals seeking registration in Ireland in the event of the UK leaving the EU without an agreement. 

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The Current System
The EU Professional Qualifications Directive (PQD) (2) governs the mutual recognition of professional qualifications in architecture(3) between EU/EEA Member States. Member States may also recognise professional qualifications of non-EU/EEA nationals in national law (4).  

Currently there are two systems relevant to UK registered architects seeking recognition of professional qualifications in Ireland: the automatic system (5) and the general system (*6).

Automatic Recognition (Admission Route D1)
The automatic system applies to persons who are EU/EEA nationals, have a recognised qualification in architecture listed in the Annex (7) of the PQD, together with the appropriate accompanying certificate(*8) if applicable.

If you satisfy the above criteria you are eligible for registration as an architect in Ireland.
In Ireland this is known as Route D1 and the fee for admission to the Register through this route is €145.

General System Recognition (Route D2)
If you are an EU/EEA national and acquired a qualification across two or more Member States(*9) or have a formal qualification from another Member State that is not listed in an Annex to the PQD, or qualified outside the EU/EEA but have been recognised by an EU/EEA Member State for more than three years your application for admission is considered under the general system.

In Ireland the general system route is known as Route D2 . The application fee for Route D2(*10)  where further assessment is not required is €145.

Status of UK Nationals after the Withdrawal Date
On the withdrawal date UK nationals will no longer be EU/EEA nationals and will no longer benefit from EU/EEA rights under the PQD. UK nationals will no longer have access to the register through Routes D1 or D2. UK nationals will be third country nationals.

Non-EU/EEA Applicants (Route B) (11)
Applicants that are not EU/EEA nationals are assessed under national law via Route B. After the withdrawal date it is probable that a UK national who was awarded a qualification listed in an Annex to the PQD together with the appropriate accompanying certificate prior to the withdrawal date would not be required to undergo further assessment. In such circumstances a UK national would most likely be eligible for admission to RIAI membership and subsequently admission to the Register. The application fee for Route B where further assessment is not required is €145.

Recognitions of Professional Qualifications Recognised Before the Withdrawal Date (EU/EEA Nationals)
Brexit will not affect decisions made in relation to the recognition of professional qualifications awarded in the UK before the withdrawal date. This means that for the purpose of automatic recognition the RIAI will continue to recognise any UK formal qualification listed in an Annex to the PQD awarded to an EU/EEA national prior to the withdrawal date.

Recognition of Professional Qualifications after the Withdrawal Date
UK nationals will be assessed for admission to the register via national law: Route B. However it is probable that only that part of your qualification which is not prescribed in Irish law or not listed in an Annex to the PQD and awarded prior to the withdrawal date will need to be assessed.

Qualifications awarded in the UK after the Withdrawal Date
Qualifications awarded in the UK after the withdrawal date are third country qualifications for the purpose of EU law. Recognition of such a qualification will cease to be covered by the PQD but will be covered by national law.

For the purpose of registration under national law the RIAI proposes to recognise UK formal qualifications in architecture listed in Annex V that were awarded to persons after the withdrawal date where that person had applied for admission onto such a course prior to the result of the Brexit referendum on 24 June 2016(*12). The RIAI will also accept the appropriate certificate accompanying the evidence of such qualification issued by the ARB.


Brexit FAQ’s

What is the effect of a no-deal Brexit on me if:

1. I was admitted to the RIAI Register based on my UK qualifications
Your registration is not affected.

2. I hold a UK qualification listed in an Annex to the PQD and I want to register in Ireland
All UK qualifications listed in an Annex of the PQD on the date of the withdrawal of the UK from the EU/EEA that were awarded prior to the exit date will continue to be recognised by the RIAI and will not be affected by Brexit.

3. I am a UK national and I want to register in Ireland so that I can maintain my Directive rights
After the withdrawal date UK nationals will no longer benefit from Directive rights such as automatic recognition or provision of services on a temporary and occasional basis. Only persons with EU/EEA nationality can benefit from rights under the Directive.

4. I am a UK national eligible for automatic recognition. I have submitted a complete application for registration under Route D1 the day prior to the withdrawal date. Will I have to reapply via Route B?
No. All applications received prior to the withdrawal date will be processed to conclusion.

5. I am a UK national with temporary and occasional registration in Ireland
Your temporary and occasional registration will expire on the withdrawal date as you will be neither an EU/EEA national nor established in a Member State.

6. I am an EU/EEA national established in the UK with temporary and occasional registration in Ireland
Your temporary and occasional registration will expire on the withdrawal date because the UK will no longer be an EU/EEA Member State.

7. Will Brexit delay my application for registration?
Brexit will not affect the manner in which the RIAI processes applications for admission to the Register and no inordinate delay is anticipated. There has been an increase in applications due to Brexit but to date this has not affected the processing time for applications.

8. I started studying for my Annex V qualification in architecture in the UK before the Brexit referendum
The RIAI proposes to recognise the qualifications of persons who commenced their course of study prior to the Brexit referendum of 24 June 2016.

9. I started studying for my Annex V qualification in architecture in the UK after the Brexit referendum
Recognition in this situation will be dependent on any future agreement between the EU/UK and/or IRL/UK as to the UK agreeing to maintain the minimum training conditions set out in Article 46 of the Directive.

10. Where can I find guidance and application packs for registration?
Further information and guidance can be found on the Admissions section of the RIAI website https://www.riai.ie/admissions/architects/

Admission to the RIAI Register/RIAI Membership

11. Where can I find guidance and application packs for Admission?
Further information and guidance can be found on the Admissions section of the RIAI website https://www.riai.ie/admissions/architects/

12. What application Route is applicable to me?

  • Route D1: You are an EU National and have completed Part 1, 2 and 3 in the UK.
  • Route D2: You are an EU National and have completed your qualifications across two EU member states (e.g. Ireland/UK) and are registered to practice with the ARB
  • Route B1: You are an EU National and have completed your qualifications across two EU member states (e.g. Ireland/UK) but are not currently registered to practice in another EU member sta Route D1: You are an EU National and have completed Part 1, 2 and 3 in the UK.
  • Route D2: You are an EU National and have completed your qualifications across two EU member states (e.g. Ireland/UK) and are registered to practice with the ARB
  • Route B1: You are an EU National and have completed your qualifications across two EU member states (e.g. Ireland/UK) but are not currently registered to practice in another EU te

13. What documents do I have to submit with my application?
The required documents are listed on the Application Form and are explained in the Applicant Guidance. Incomplete applications cannot be processed. Please ensure you submit all requested documents including Original documents, where requested. A registration certificate cannot be accepted in place of any Directive 2005/36/EC statement or attestation.

14. Can I email my application?
Applications cannot be accepted by email.

15. Do I have to pay a fee with my application?
All Admission Routes incur a fee, which is noted on the Application Form along with the payment options. The fee is a once-off administration fee, payable on application that covers the cost of processing and evaluating the application. The Application and Admissions Procedure is outlined in the Applicant Guidance.

16. What is the difference between Registration and RIAI membership?
The title architect is protected in Ireland, so to describe yourself or your practice using the word architect you have to be registered. You can view the RIAI fee schedule on https://www.riai.ie/admissions/fee_schedule/
RIAI Membership is optional and currently free. Membership benefits can be viewed on the Admissions website http://www.riai.ie/admissions.

17. How do we register our practice?
RIAI Practice Membership is the term used to describe practice membership of the RIAI. This is distinct from both individual membership and statutory registration. Practice Membership with the Institute is available to MRIAI or FRIAI members. Information on RIAI Practice Membership is the last item on https://www.riai.ie/admissions/fee_schedule/


  1. Brexit refers to the date on which the United Kingdom withdraws from the European Union. Currently this is scheduled for 29 March 2019.
  2. Directive 2005/36/EC on the recognition of professional qualifications and the European Union (Recognition of Professional Qualifications) Regulations 2017
  3. The mutual recognition of professional qualifications in architecture is based on an agreed minimum standard set out in Article 46 of the PQD.
  4. In Ireland the Building Control Act 2007
  5. Title III Chapter III of the PQD and section 15 of the Building Control Act 2007
  6. Title III Chapter I of the PQD and section 16 of the Building Control Act 2007
  7. There are two Annex relevant to the architects: Annex V point 5.7.1 and Annex VI
  8. In the UK the Accompanying Certificate is the Part 3 Certificate. In Ireland it is the Certificate of Fulfilment of Qualifications Requirements for Professional Recognition as an Architect in Ireland.
  9. For instance a formal qualification from one Member State and an accompanying certificate from a second Member State - this is known as a mixed qualification.
  10. The RIAI may require certain applicants under Route D2 to confirm their knowledge, skill and competence in the context of the RIAI Standard of Knowledge Skill and Competence for Practice as an Architect. This may require an interview or an assessment or the application of a compensation measure. However it would be unusual to require further assessment where a candidate has an Annex V UK/Ireland mixed qualification.
  11. Route B provides a route to registration for non EU/EEA nationals. It also allows an applicant who does not meet the criteria for Routes D1 or D2 to demonstrate that they a have met the required standard. The RIAI may assess qualifications for  equivalence with the PQD and applicants may be required to demonstrate their knowledge by self-assessment and/or interview. Candidates may also be required to undergo compensation measures.
  12. The Brexit referendum refers to the United Kingdom European Union membership referendum that took place on 23 June 2016. The result of referendum was announced on 24 June 2016.

Published: 8 March 2019

Categories: Architecture | Brexit


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