ACA Response to Victorian Framework for Reform

31 May 2021

After extensive consultation, the ACA’s VIC/TAS Committee has submitted its response to the Victorian government’s Framework for Reform building review.

Key priorities include the preservation of the Architects Act 1991 and appropriate consumer protections; strengthening of the ARBV and CPD for Architects; incentivising more architectural registrations; the establishment of minimum documentation standards; maintaining the independence of architects and building certifiers; and regulating unregulated disciplines.

Our executive summary outlines the ACA’s key priorities and the full submission is also available for download for further background and discussion of the issues.


“Architecture is a globally connected and integrated industry. To significantly improve consumer protection and ensure product quality and economic viability, we cannot make unilateral regulatory changes as a state without considering the national and international implications of such reforms. In principle, we support the consumer protection intentions inherent in the FFR and the BCR before it.

We recognise the fundamental, interdependent relationships between design and construction industry practitioners and believe that any reforms must be carefully considered. It is our view that the positions and recommendations noted will contribute to achieving the desired strengthening of building quality and more appropriate regulatory controls, without diminishing the established gains as legislated for our profession.

The ACA stands ready to contribute to a reform framework that would propose robust, workable solutions for the broader industry, and maximum consumer confidence in buildings constructed to the highest possible design standards.”

—Paul Viney, ACA – VIC/TAS President



The ACA broadly supports the intent of the Framework for Reform: Modernising Victoria’s Building System discussion paper (FFR) to achieve industry reforms that will tackle issues of building quality, consumer confidence, industry skills and improved regulatory compliance. Acknowledging the scale and complexities of the problems outlined below, we summarise here our position and recommendations for the Panel.

1. Creation of a Chief Regulatory Body and Independent Design and Construction Discipline Boards

The ACA supports the establishment of a Design and Construction Practitioners Coordination Board (DCPCB) or similar that could oversee the quality of work and compliance industry-wide (see below). This entity would contain independent boards from each design or construction discipline responsible for delivering to compliance requirements as set out in the National Construction Code (NCC). Independent boards should be responsible for the accreditation, registration and compliance of their respective constituents.

2. Maintain the Architects Act 1991

Architects are governed by a consistent national competency and registration framework as set out in the Architects Act 1991 (the Act). Any registration and competency framework reforms should seek to preserve the established value architects offer by meeting these requirements, as enshrined in the Act. We don’t believe that amendments to the Act will achieve the desired strengthening of building quality or longevity, or greater regulatory control, and could have unintended detrimental impacts outside Victoria on broader reform work and on university level qualifications more broadly.

There is a very real risk to quality design and construction should changes be made to the Act; therefore, reform measures and greater regulatory controls must be sought in the establishment of appropriate governing bodies and in the strengthening of existing regulators such as the Architects Registration Board of Victoria (ARBV). Whilst we would prefer the existing Act be retained, any amendments to this Act, or proposed future Act governing the work of architects, must ensure the terms Architect, Architecture and Architectural are legally protected and the obligations under the Victorian Architects Code of Professional Conduct be maintained for appropriate consumer protection.

3. Maintain and Strengthen the ARBV

The ARBV regulates the architectural industry in Victoria, operating under the Act. It offers a high standard of consumer protection through its independent regulation and governance of registration, accreditation and Continuing Professional Development (CPD). The ACA’s preferred model would be to strengthen the ARBV’s functions, as enshrined in the Act. Increased revenue through a rise in registration fees, and a drive for new registrations, would support this.

4. Strengthen CPD for Architects

The relevance of CPD must be strengthened and amended to support improved quality outcomes and currency of best practice standards. Changes to CPD should include a compulsory component dedicated to the NCC and Australian Standards training.

5. Incentivise More Architectural Registrations

The ACA believes there are many benefits to encouraging higher numbers of architectural registrations, including improved quality of design outcomes and the better resourcing of the ARBV to perform its crucial task. Reforms should consider how more Architectural Graduates with an appropriate level of experience could be incentivised to become registered.

6. Minimum Documentation Standards

We support the establishment of minimum documentation standards based on the NSW model for regulated design, along with the establishment of appropriate independent compliance and quality checks throughout the construction process.

7. Maintain Architect and Building Certifier Independence

Independent architects and building surveyors ensure better consumer protection and confidence. The ACA recommends any reforms must preserve this independence and strengthen the capacity of independent assessors to improve quality outcomes and increase consumer confidence. It is also the ACA’s view that contracts that limit the independence of architects and building surveyors to comply with their obligations under the Act should be prohibited.

8. Regulation of Unregulated Disciplines

The ACA supports the principle of registering previously unregulated disciplines (e.g., project managers, construction managers, superintendents and other individuals overseeing building contracts). The registration of and compliance activities must be governed by the appropriate Boards and structures, as set out in the first point and diagram above. We also support the appropriate qualification and registration of building practitioners of any discipline proposing to undertake Class 2 projects work and any work on complex buildings.

Download the ACA Response

You can download the full ACA Response to the Framework for Reform: Modernising Victoria’s Building System discussion paper here: ACA_VIC_Response_to_Framework_for_Reform_Building_Review_May21


Thank you to the ACA VIC/TAS President Paul Viney and ACA National President John Held for their enormous efforts in coordinating this response and ensuring that the ACA has a seat at the table as the consultation process proceeds. Also, thanks to VIC/TAS Committee members Kirby Roper, Daniel Haskell, George Theodoridis and David Wagner, and ACA’s Research Director Peter Raisbeck for their invaluable contribution.

Particular thanks also to Jo McErvale from Word to the Wise, and Paul Guerra (Chief Executive Officer) and Dylan Broomfield (General Manager Policy and Advocacy) from the Victorian Chamber of Commerce & Industry.

We would acknowledge the sage advice from a range of interested parties including Former Premier the Hon. Ted Baillieu AO, Former Minister Planning the Hon. Justin Madden, VBA Commissioner Yvonne Von Hartel AM, and Parliamentary Secretary Mr Peter Lochert.