Related on Archinect: Henning Larsen’s ‘forest canopy-like’ World of Volvo opens in Sweden. Image credit: Rasmus Hjortshoj

In the third part of Archinect In-Depth: Licensure, we reflect on what the United States can learn from the architecture licensure models of other nations. While doing so, we speak with Peggy Deamer, Professor Emerita of Yale University's School of Architecture, whose book Architecture and Labor includes an analysis on how the wider U.S. architecture profession compares to those of France, Germany, and Sweden.

The Grass Is Always Greener

Growing up in the Republic of Ireland, I was required to study the Irish language from an early age. One of the earliest Irish phrases I learned was “Is glas iad na cnoic i bhfad uainn,” which translates directly as “The faraway hills are greener.” Despite its appropriateness for Ireland’s landscapes, the proverb isn’t uniquely Irish. In ancient Rome, one might have used the phrase “Fertilior seges est alenis semper in agris,” meaning “The harvest is always more fruitful in another man's fields,” while the widely-used English version “The grass is always greener” dates back to at least the 1920s with Raymond B. Egan and Richard A. Whiting’s song The Grass is Always Greener in the Other Fellow’s Yard.

Given the many critiques we often hear from readers on the current U.S. system, from the cost and time required to complete the path to a lack of support to demographic inequalities, surely the grass had to be greener somewhere else?

What can any of this tell us about architectural licensure? A couple of things, actually.

Firstly, it speaks to an intrinsic human tendency to engage in comparisons. The practice of comparing ourselves to other individuals has been a staple of the human psyche since time immemorial. However, we don’t stop there. In addition to subjecting ourselves to individual comparisons, we also subject our national systems to comparisons with other countries. Indeed, some of the most charged political and social debates in the U.S. place international comparisons at their forefront, including the healthcare system, gun rights, immigration, labor laws, and drug policies. As our proverb alludes to, these comparisons only run in one direction: up. From the perspective of U.S. change agents, the grass is always greener for the UK’s National Health Service, Portugal’s liberal drug policies, or Austria’s mandatory 43 annual paid vacation days.

The same holds true for Archinect In-Depth: Licensure, where one of the first lines of inquiry agreed upon within our editorial team was to compare architectural licensure in the U.S. to other countries. Given the many critiques we often hear from readers and commentators on the current U.S. system, from the cost and time required to complete the path to a lack of support to demographic inequalities, surely the grass had to be greener somewhere else?

Learning from Europe

We weren’t the only ones to begin with this premise. In her 2021 book Architecture and Labor, Yale University Emeritus Professor of Architecture and long-time Archinect contributor Peggy Deamer expressed the same sentiment about the U.S. architecture profession as a whole, writing: “My interest in examining professional architectural organizations outside of the United States began with the conjecture that other countries probably did more to address an unrewarding and increasingly irrelevant profession than the American Institute of Architects (AIA), an association that has proved indifferent to a faltering discipline.”

Deamer’s mission of exploring how other countries structure their architectural professions took her through three case studies: France, Germany, and Sweden. Before reflecting on the conclusions Deamer drew from her research, however, it is worth taking a moment to briefly introduce these three systems, if only as a demonstration that the U.S. model of architectural professional and licensure structures is not ubiquitous, even across the wider geopolitical West.

Unlike the United States, there is no final ARE-style licensure exam in France.

To be recognized as a licensed architect in France, one must become a member of the Ordre des Architectes, a national professional architecture association regulated by the national government’s Ministry of Culture. To become a member, and hence a legal architect, one must graduate from an accredited architecture school, which typically lasts five years, in addition to completing a one-year apprenticeship. Unlike the United States, there is no final ARE-style licensure exam in France.

While French licensure is centralized via the national Ordre, Germany sees architectural licensure devolved to the country’s 16 regions, each of which contains a branch of the national, semi-public Federal Chamber of German Architects (Bundesarchitektenkammer e.V. – BAK). To become a legal architect, a candidate must join their regional kammer by completing an academic degree, which normally takes 5-6 years, in addition to at least two years of practice. As with France, no ARE-style professional examination is required.

In her summary of the German system, Deamer points to a peculiarity that, though not pursued further in this article, is worth noting. “German architects hesitate to pursue licensure because the two-year apprenticeship is so difficult and because, in a field dominated by large firms with the large teams needed to complete technologically complex buildings, many are certain they will never need to stamp a drawing,” Deamer notes. “As a result, 50% of those graduating from accredited architecture schools in Germany do not complete registration.”

Unlike the U.S., anybody in Sweden can call themselves an architect. There is no legal protection on the title.

Of our three case studies, Sweden is arguably the most intriguing. Unlike the U.S., anybody in Sweden can call themselves an architect. There is no legal protection on the title. In the eyes of clients and the public, faith in an architect’s competence instead rests on whether or not their architect is a member of Sveriges Arkitekter, translated as Architects Sweden, which serves as both a professional organization and a labor union. To join the association, one must graduate from an accredited school of architecture, interior design, landscape architecture, or spatial planning, in Sweden or the European Union. There is no ARE-style exam, nor AXP-style measure of experience. It is interesting to note that, despite the fewer qualifying hurdles one has to overcome to join the Swedish association, and the lack of protection of the title ‘architect,’ Swedish architects are among the highest paid of their profession in Europe. “The securer the title, the lower the fee,” one Swedish official told Deamer.

Architecture and Identity

While Deamer began her study with the goal of learning from the architectural professions of other countries, and using such models as a catalyst for transforming the U.S. system, she instead found such a goal to be, in her own words, “misplaced and rather naïve.” This brings us to the second lesson our ‘faraway hills’ proverb can teach us about architectural licensure. From a distance, such landscapes can appear Nirvana-like, if only we could reach them. When we do, the complexities and flaws of our new surroundings reveal themselves, while newer, more promising, greener hills come into view. Such a pursuit of perfection through direct comparisons and transplants is not only endless but arguably flawed, our proverb tells us.

“The examination of architectural organizations in France, Germany, and Sweden,” Deamer writes, “revealed more than anything how deeply steeped these organizations are in their own national heritage and, hence, the non-importability of their models to the United States. While there are lessons to be learned about how architectural associations everywhere can more effectively nudge architecture into the public consciousness as a focus of national concern, the overriding revelation is how much architecture is used as an agent of nationalist ideology.”

The French architectural profession, for example, is intertwined with a French cultural context that views architecture as a principal source of national pride. While France’s highly centralized political and economic structure results in an architectural professional body directed and funded by the state, the importance of architecture as a symbol of French cultural identity results in a competition-heavy procurement process for architects which, for Deamer, “continues the Beaux-Arts tradition that links these competitions to the production of cultural grandeur and assures the visibility of architecture in the public consciousness.”

While there are lessons to be learned about how architectural associations everywhere can more effectively nudge architecture into the public consciousness as a focus of national concern, the overriding revelation is how much architecture is used as an agent of nationalist ideology. — Peggy Deamer

Where France’s profession serves as a vehicle for propagating cultural splendor, Germany’s profession is structured to reflect its nation’s pride and emphasis on engineering quality and efficiency. As a result, the path to architectural licensure is informed by a need to demonstrate technical competency, before joining an architectural professional body which itself is closely aligned with engineering.

Meanwhile, as Deamer notes, Germany’s wider “pro-employee environment” results in a system where joining the kammer not only makes one a legal architect, but creates a formal written employment contract with the kammer, offering members a pension, labor support, and a de-facto fee schedule despite the European Union’s tough competition laws. “Architects pay a portion of their monthly salary to the government, which, in turn, filters it back to the kammers,” Deamer explains. “This system helps connect individual architects to the system at large and to each other.”

Finally, Deamer argues, Sweden’s model of the architecture profession is “a product of the knowledge economy and innovation,” where firms and institutions alike can gain access to research funding, particularly for innovation across construction, design, the environment, and finance. The architecture profession is also emblematic of a wider national emphasis on the experience of a system’s ‘end user.’ This preoccupation on the social value of architecture is reflected not only in Sveriges Arkitekter’s dual role as a professional body and labor union but also in the absence of any protection on the use of the title ‘architect.’ The average citizen is seen as a participant in the architectural process, echoing a wider political outlook which Deamer describes as “bottom-up openness and top-down control.”

In a recent conversation on the topic, I asked Deamer whether she believes this observation on the link between a country’s architectural professional structure and a wider national identity extends beyond her European case studies to more geographically and culturally distant regions such as Asia. “One hundred percent,” Deamer told me. Taking China as an example, she pointed out that “it is only in recent years that you can study with a major in architecture. They didn’t want to license architects as it was seen as bourgeois.” Deamer also pointed to the recent emergence of private practice in China, as opposed to the traditional model of architects working for the state. “They're going through a period right now about how to deal with people who aren't just totally within the system,” Deamer added.

Provocations, Not Solutions

When asking what these findings can tell us about the future of architectural licensure in the United States, two conditions are worth highlighting. The first relates to licensure’s relationship to the wider profession. Just as the architectural profession exists in a country’s wider political and cultural outlook, the licensing system itself exists as only one domain in the wider architectural profession. In our conversation on the topic, Deamer went further by noting that, in her view, radical reform of professional organizations such as the AIA takes precedence over isolated reform of licensure.

This raises a question: is the strength of feeling about licensure and protection of title among the U.S. architecture profession a consequence of a fragmented professional landscape? Returning to our three case study countries, we see a profession where licensure is dissolved into the workings of organizations whose responsibilities also encompass lobbying, professional promotion, employee support, and the administration of research and commercial opportunities. By contrast, both the U.S. and the United Kingdom operate a model where, to some, membership of a licensing body provides little more than permission to use the title ‘architect.’ However, while this divorce between licensing boards and professional bodies may lessen the wider impact of licensure reform on the profession, it may also offer the U.S. profession the freedom to enact licensure reform without the weight of adhering to cultural or political hegemony.

Is the strength of feeling about licensure and protection of title among the U.S. architecture profession a consequence of a fragmented professional landscape? 

This brings us to our second condition: architecture's perceived lack of cultural or political value in the United States. “Unlike France (which views architecture as a source of national pride), Germany (which views buildings as demonstrations of technical expertise), or Sweden (which understands its built environment as a social experiment), the United States has no particular collective view of architecture other than an ability to build tall skyscrapers that speak to capitalist development,” Deamer notes in her book. There are several explanations for this. Compared to European nations, the U.S. covers a vast variety of geographical and cultural contexts, each of which can demand its own architectural needs and agendas, encouraged by a constitutional system that propagates legislative divergence among states versus more centralized European nations. For Deamer, the U.S. reverence for the private free market versus a more socialist outlook in Europe also contributes to architecture’s disempowerment.

“The fact that most of the projects that architects get in the U.S. are private makes it much more difficult for there to be a connection between how architecture is represented in the state and, consequently, how architecture is represented in the public,” Deamer told me. “Unlike these European countries, most big projects are not public, making it difficult for the public to say that a specific piece of architecture represents pride in the U.S.”

As we ask how the U.S. architectural licensure system should evolve, then, perhaps there is value in looking to the rest of the world not for solutions, but for provocations.

As we ask how the U.S. architectural licensure system should evolve, then, perhaps there is value in looking to the rest of the world not for solutions, but for provocations. Without replicating the French Ordre des Architectes, might we nonetheless reflect on how a nation that sees architects as indispensable for the delivery of national monuments, and a national identity, can do so without requiring an ARE-style final examination? Without replicating the German kammers, might we ask how membership in a licensing body could become more than an end in itself, but provide stronger professional benefits or resources to license holders? 

More radically, might the example of Sveriges Arkitekter invite us to reflect on whether protection of the title ‘architect’ is the only strategy available to protect the integrity of the architectural profession, and the health and safety of the public?