When the United Kingdom left the European Union on January 1, the country’s architects lost the blanket right to work across continental Europe. It appears as if an epoque in which British architects worked successfully at the heart of the continent—projects such David Chipperfield Architects’ renovation of the Neues Museum in Berlin and Zaha Hadid’s bravura design for the MAXXI, the contemporary art and architecture museum in Rome—was suddenly over. Now British architects are dependent on regulations within each nation to allow them to work in Europe.
Despite the intense negotiations that took place between officials in Brussels and London throughout 2020 that produced a trade deal, no specific agreement on the reciprocal recognition of all professional services, including architects, was reached, and individual countries have the right to treat UK qualifications as “rest of the world” qualifications.
“It will now depend on member state by member state,” says David Green, director of Belsize Architects and the former head of the European Division of the Bank of England. “Each will decide whether they are happy to recognize our qualifications. The UK has decided on an interim basis to recognize EU qualifications, as in the past, but this will be subject to review.” This is likely to be a drawn-out process, but it has already begun. The Architects Registration Board (ARB) in the UK has recently reached an agreement with the Royal Institute of the Architects of Ireland that enables architects in either country to register under the same process that existed prior to January 1st.
The process of unilaterally recognizing British qualifications is completely random. The ARB is also aware that their Spanish counterparts are planning to retain a component of the EU, so UK-qualified individuals will have their qualifications recognized in Spain: an acknowledgement that, although subject to review, Britain has recognized the qualifications of the many Spanish architects working in the UK. “We are awaiting information from other EU States in terms of the arrangements they have put in place,” says a spokesperson for the ARB.
As to winning work in Europe, the process is still unclear. It will certainly be more complex and require greater forethought, however, the situation is effectively a complication of the pre-existing process rather than an entirely new one. Amin Taha, principal of the British practice Groupwork says, “When you are working abroad, you always need to find a local architect to help you with planning laws and building regulations. Not just in competitions, but in any kind of contract. You can’t just go piling in, so you find a local architect who knows the politics and the planning.”
After leaving the EU, Taha believes that British architects will have to make partnerships with local architects much earlier in the design and building process, either before entering a competition or as soon as they are approached by a client outside of the UK. This extra layer of difficulty may tip the balance against some British firms opting to seek work abroad. Richard Haut is the former publisher of Competitions magazine and a consultant to architects on winning work. He agrees that “it was extraordinarily stupid in Brexit negotiations that nothing was done to ensure that the automatic recognition of qualification was guaranteed beyond Brexit.”
However, he believes that economic necessity and exciting briefs will still encourage British architects to seek work in the European Union through partnerships with local architects. Given the general international economic uncertainty caused by the pandemic and the ensuing lockdown, the European procurement system offers relative stability. “Generally, the procurement system in Europe is light years ahead of Britain. Among the best in the world is the French one, where those who run projects must, by law, have money in the bank and you are paid to produce work for competitions. What has surprised me, is why British architects didn’t use it more when it was easier,” says Haut.
Both culturally and economically the ties that bind the UK and Europe to each other will continue to be strong. Indeed, the effects of the pandemic may encourage British architects to overcome the short-term difficulties and strive even harder to work in Europe.
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