RIAI CPD for Registered Architects: The Irish Regime Where Non-Compliance Means Removal From the Register

Irish regulated professions differ enormously in what actually happens to someone who ignores their CPD obligation, and the range is wider than most practitioners assume. At one end sits a statutory duty with no sanction at all. At the other sit registered architects, where the governing statute does not give the regulator a discretion to remove a non-compliant registrant. It obliges it to.

That makes architects the hardest CPD regime in Irish professional regulation, and it is worth understanding precisely, because the enforcement has only recently become real.

The register, and why the title matters

The statutory register of architects is maintained under Part 3 of the Building Control Act 2007, comprising sections 13 to 27, and it launched on 16 November 2009. The Royal Institute of the Architects of Ireland carries out the statutory functions of Registration Body and Competent Authority, and does so on a self-funding basis.

The consequence is simple and often misunderstood: to use the title "Architect" in Ireland a professional must be on that register. Registration is not a membership badge layered over an unrestricted profession. It is the gateway to the title, and continuing professional development is a condition of remaining on it, alongside compliance with the Architects' Code of Conduct.

What the obligation requires

Under the policy introduced for the 2023–2024 cycle, Registered Architects must complete at least 40 hours of CPD each year, of which at least 20 hours must be structured. The cycle runs from 1 December each year to 30 November the following year, which is why 30 November is the date that matters rather than any calendar or financial year end.

Records are kept on the MyRIAI CPD platform, with a derogation available for hardcopy records. Evidence upload now applies only to those selected for CPD audit, which means the ordinary obligation is to log activity contemporaneously and the evidential burden arrives only if you are sampled.

A caution on the figures. The RIAI's current CPD policy summary page confirms the MyRIAI recording route, the 30 November deadline, that an audit process is running, and that the policy covers Registered Architects and Architectural Technologist Members — but it no longer restates the hour requirements, pointing instead to the full policy documents. Anyone relying on a specific number for the live cycle should take it from the current RIAI policy PDF rather than from any secondary account, including this one.

Section 17A, which is the whole point

Here is what separates this regime from every other Irish CPD framework. Under section 17A of the Building Control Act 2007, the RIAI must remove from the Register any Registered Architect who fails to comply with the RIAI CPD system.

Read the verb. Not "may remove". Not "may consider removal following a review". The obligation to remove sits on the regulator, and because the title is protected by registration, removal is not a sanction against a credential. It is the loss of the right to practise under the name of the profession.

There is a remediation path before that point, and it is short. Where a CPD record is marked unsuccessful, the Registrar notifies the architect, who then has until the first Monday in April to amend the record or complete additional CPD. That is a window of roughly four months from the end of the cycle, and it is the only one.

The soft launch, and why history is misleading here

The 2023–2024 cycle was run as a soft launch. No architects were removed from the register for non-compliance in that cycle, and the RIAI stated an aim of 100% compliance for 2024–2025.

This matters for how the risk is assessed internally. A practice that has never seen a colleague removed for CPD failure may reasonably have concluded that the obligation is nominal. The absence of removals during a declared soft launch is not evidence that removal will not happen once the launch period is over, and the presence of live audit documentation for the 2025 cycle suggests the process is now operating normally.

Where this sits against the other Irish regimes

Placing architects on a spectrum is the quickest way to see what is unusual about them. Four Irish CPD regimes, ordered by what non-compliance actually costs:

• Registered architects — 40 hours annually, 20 structured, and a statutory obligation on the regulator to remove the non-compliant from the register.
• Veterinary practitioners and nurses — a credit requirement where the activities themselves must be accredited by the regulator, so relevance is pre-decided but the choice of provider is restricted. We set out the detail in our guide to the Veterinary Council of Ireland's CPD requirements.
• CORU-registered health and social care professionals — 30 credits a year, audited on a sample, with no accredited provider list at all, so the registrant carries the burden of justifying relevance. Our guide to CORU CPD requirements across the allied health professions covers the framework, and the radiographers trend report shows what the regulator actually finds at audit — a minority met the recording standards on first submission.
• Public bodies under the equality and human rights duty — a mandatory statutory duty with no sanction whatsoever and no cause of action, as we set out on section 42 of the IHREC Act.

The pattern worth noticing is that severity of sanction does not track the amount of CPD required. Architects do 40 hours under threat of removal; CORU registrants do 30 credits with a remediation process; public bodies face an unquantified duty with no consequence. Practitioners who assume the hours indicate the seriousness of the regime have it backwards.

What the regimes have in common

Two features recur across all of them, and they are the two that cause failures.

The first is sampling. Architects upload evidence only if selected for audit; CORU audits a sample of each profession in turn. In both cases the obligation to record runs continuously while the obligation to produce evidence arrives without warning, which means a portfolio assembled after a notice lands is assembled under exactly the wrong conditions. The published CORU findings on professions with small registers make the point that a small register does not mean a light audit — it means the regulator has capacity to look closely.

The second is that the regulator sets a floor and the practitioner chooses the content. The RIAI's policy makes each Registered Architect and Architectural Technologist Member responsible for judging how much and what type of CPD they need, with general freedom to choose relevant topics. That freedom is also the exposure: a selection that cannot be explained by reference to the person's actual scope of practice is harder to defend than a thin one that can. Other Irish professional frameworks take the same approach, including the Teaching Council's Cosán framework and the requirements of the Opticians Board.

Our suggestions

Three things for a registered architect or a practice managing several.

Work to 30 November, not to the end of the year, and treat the first Monday in April as the genuine cliff rather than the deadline. The remediation window exists but it is the last one, and it closes while most people are still thinking about the previous cycle.

Take the hour requirements for the live cycle from the current RIAI policy document rather than from any summary. The policy has already changed once, the summary page no longer carries the figures, and the sanction for getting it wrong is not a fine.

And log structured activity as structured at the time it happens. The structured component is the part with a specified minimum, and reconstructing afterwards whether a given session met that description is the kind of judgement that looks like reverse-engineering when an auditor reads it.