With respect to the 2021–2023 amendments to the Fair Access to Regulated Professions and Compulsory Trades Act (FARPACTA), many professional regulators have been compelled to revise their registration practices. More specifically, through FARPACTA, the Ontario Fairness Commissioner (OFC) and the Ministry of Labour, Immigration, Training, and Skills Development (MLITSD) have mandated the need to establish alternative methods to evaluate Canadian experience.
It has been the OAA’s position that local Ontario practice knowledge is critical to public health and safety and the provision of competent architectural services in Ontario; as solidified in the January 2023 FARPACTA exemption request. Given this position, the OAA will now assess that applicants can demonstrate competency in specific areas of Ontario practice. This aligns with the OFC’s focus on assessing competencies rather than criteria.
The OAA has revised the Ontario licensure requirements in the following ways:
These changes have been implemented to establish a method to assess the architectural competencies specific to Ontario practice and an alternative to acquire knowledge of practice in Canada prior to professional practice.
The requirements are unchanged for individuals who wish to record and submit post-graduate international architectural experience gained outside of Canada while not enrolled in an OAA internship program. Namely, if any international experience gained while not in the Internship in Architecture Program (IAP) or the OAA Technology Program (OTP) forms part of the experience submission at the time of making application for licence or limited licence, the applicant will be required to attend an assessment interview with the OAA Experience Requirements Committee (ERC).
(Until December 31, 2024, there was a transition period to minimize any disruption to Intern Architects who are close to completing their experience hour requirements. Any Intern enrolled in the IAP beginning January 1, 2025 must complete the requirements above.)
Existing Intern Architects who wish to transition to the new requirements prior to December 31, 2024 should contact the OAA at iap@oaa.on.ca.
The OAA worked with provincial government Ministries as well as the Office of the Fairness Commissioner (OFC) to examine how the Association’s licensure requirements can satisfy the FARPACTA amendments, while maintaining the standards of the profession and administering the Architects Act to serve and protect the public interest.
These changes are intended to make the process more equitable, efficient, inclusive, and transparent for all applicants, as well as satisfying the new FARPACTA requirements.
How is the OAA responding? What is its proposed alternative?
As detailed in the November 16, 2023 edition of OAA News, discussion on changes to FARPACTA with respect to Canadian Experience Requirements (CERs) has been a regular agenda item for the OAA’s governing Council since early 2022. You can find more information in the meeting packages and also read correspondence with the provincial government on the OAA Website.
The OAA has worked closely with the OFC and the Ministry of Labour, Immigration, Training, and Skills Development to establish procedures and policies that will satisfy the new FARPACTA requirements. Concurrently, MLITSD has prepared criteria for CER alternatives that have now been enacted in the Regulation under FARPACTA.
The OAA is obligated to administer the licensure requirements established in the Architects Act and its Regulation 27. To date, the requirement for direct Ontario work experience had been set out in the Regulation. In order for the OAA to revise the licensure requirements, amendments to the Regulation had to be proposed, accepted, and enacted by the provincial government.
The OAA’s proposal amended the licensure requirements of Section 31 of Regulation 27. More specifically, the OAA submitted a proposal that establishes licensure requirements for individuals who have limited architectural experience in Canada, while also recognizing the importance of establishing Ontario practice competency or its equivalent.
These changes suggest neither a reduction in the total number of required experience hours nor revisions to experience categories. Rather, it proposes a method to assess the architectural competencies specific to Ontario practice and an alternative to acquire knowledge of practice in Canada prior to applying for licence or limited licence. The internship programs will maintain all other requirements inclusive of the academic credentials, OAA Admission Course, and the licensing examinations.