Evaluation of Compliance culture in Victoria

A. Overview

Objective of chapter:	To gain an understanding of the compliance culture that currently exists within the architecture sector in Victoria.
Importance:	An understanding of the compliance culture across the profession enables the ARBV and other regulators of architects across Australia to identify systemic compliance issues that may exist. It also enables regulators to develop targeted strategies to unpack and address compliance issues in collaboration with architects and architectural firms, as well as other participants in the broader construction sector.
Key insights:	Architects generally demonstrate a strong commitment to compliance, which reflects an appreciation of their professional responsibility to uphold high standards. However, this commitment may be undermined by project realities and complexities, including but not solely in the context of D&C procurement. Tight timelines, unclear roles and responsibilities, and builder control of project decisions may undermine architects’ capacity to comply. In addition, even though architects have a duty to act with honesty and integrity, fear of conflict and lack of contractual power may prevent architects from reporting or resisting non-compliance in certain project contexts. Despite this challenging and complex environment, architects need to turn their mind to compliance, even if they believe that the primary responsibility rests elsewhere or that their responsibility for compliance is confined (e.g. because they are providing partial services). Regulatory complexity and change may also make it difficult for architects to maintain compliance and competence. CPD is broadly valued by the profession, but compliance with CPD requirements is inconsistent, which signals a gap between intent and practice. Notwithstanding the challenges to comply, architects are widely seen as ethical and trustworthy, reflecting a strong professional identity. However, ongoing systemic issues within the broader construction sector may expose architects to disproportionate blame for non-compliance and could erode public confidence in the profession as well as in the broader construction sector.
Implications for architects and architectural firms	Architects need to ensure awareness of compliance and maintain an ongoing commitment to professional development, especially in the face of a complex and dynamic commercial and regulatory environment.

B. Introduction

As regulator of the architecture profession in Victoria, the ARBV views the evaluation of compliance culture as essential to fulfilling its role under the regulatory framework – namely to protect clients, the public and the profession from harm.
Evaluating compliance culture is important because it provides insights into how well legal obligations, ethical standards and professional responsibilities are understood, prioritised, and embedded in practice by members of the profession. It is difficult for the ARBV to effectively support the profession to meet their professional responsibilities without such an evaluation.
The purpose of this chapter is to evaluate the current state of compliance culture within the architecture sector in Victoria using the best available evidence.
The chapter introduces a structured framework to evaluate compliance culture in a transparent and objective way. This framework seeks to ensure that any efforts by the ARBV to strengthen compliance culture within the profession are grounded in evidence, rather than ad hoc data, anecdotal information, and assumptions that have not been fully explored and tested.
In this chapter, the evaluation framework has also been applied to gain a clearer understanding of how compliance with professional responsibilities is currently viewed and practised across the architecture profession in Victoria.
The data used to inform this evaluation includes survey responses from more than 500 members of the Victorian profession, as well as important insights from a focus group comprising key representatives from the architecture sector and the broader construction sector.

C. Framework to evaluate compliance culture

This section sets out the elements of a framework to evaluate compliance culture in the architecture sector.

Despite the regulatory benefits of understanding compliance culture, the evaluation of compliance culture across the profession presents significant challenges

Despite the benefits, evaluating compliance culture presents significant challenges, including the following:

Scope of compliance: Determining the scope of compliance to consider when evaluating compliance culture presents a key challenge. A broad, generic approach which focuses on overall attitudes toward compliance can provide useful insights into general approaches and cultural norms, but may overlook specific risks or behaviours relevant to particular obligations. Conversely, a more targeted approach that focuses on specific types of non-compliance (such as cladding or weatherproofing under the NCC) can reveal specific vulnerabilities, but may miss the bigger picture of whether compliance is valued across an organisation or sector.
Diversity of regulated entities: Within the architecture sector, architectural practices vary from sole practitioners and small firms to large, multinational firms. The type, location and scale of projects undertaken by these practices also vary. Some firms may have visible and formal compliance management systems, whereas sole practitioners and small firms may approach compliance in a more informal and less structured way. This diversity complicates an assessment of compliance culture across the profession.
Variety of procurement methods: There is a variety of procurement methods that may be used for construction projects, each of which involves different contractual structures, roles, responsibilities and allocation of risk. This variability means that compliance expectations and behaviour can differ significantly from one project to another, making it difficult to assess culture consistently.
Scope of services: The scope of consultancy services often differs between projects. This can create challenges for architects, particularly when they are expected to coordinate the input of other consultants. If those other consultants have entered into separate agreements with the project proponent which the architect is not privy to, the architect may not have full visibility over their roles, responsibilities or deliverables. This lack of transparency can affect how well coordination is achieved and may limit the architect’s ability to ensure that compliance obligations are consistently met. This also makes it difficult to assess whether compliance responsibilities are clearly defined, understood, and effectively coordinated.
Market conditions: The market for the provision of architectural services is necessarily dynamic, which means that a static assessment that assumes that compliance culture is fixed is not appropriate. Demand for architectural services may fluctuate depending upon the state of the broader economy. Financial instability among construction firms can disrupt projects. Rising construction costs can limit revenue and affect profitability of architectural practices. In addition, the level of competition faced by architectural firms may change over time depending upon the number of and types of participants providing architectural and design services. Collectively, these factors can affect the sector’s approach to compliance at a particular point in time.
Qualitative evaluation: Evaluating compliance culture is primarily a qualitative exercise because it involves assessing intangible elements like values, attitudes, expectations and aspirations of sectoral participants. These elements can be difficult to detect through the use of traditional regulatory tools and may be difficult to measure through objective, quantitative metrics.
Data limitations: There is no single source of data that can be used to assess compliance culture across a sector. Instead, consideration of a mix of various types of data will be needed to form a holistic view of culture. Each source of information may, on its own, be incomplete or biased, which adds complexity to the way in which it should be assessed individually as well as collectively. Reconciling inconsistent data also creates challenges.

In light of the above challenges, the evaluation in this report is subject to the following main qualifications:

Scope: The evaluation adopts a broad approach which focuses on overall attitudes toward compliance, while recognising that a more granular evaluation surrounding particular compliance issues could also be a useful exercise in the future.
Diversity of regulated entities: The evaluation is not focused on any particular segment of the profession (such as sole practitioners, small firms and large firms or on particular project typologies), but there could be value in such segmentation in the future.
Market conditions: The evaluation accounts for available data about current market conditions, noting that these conditions could change and affect the results of a subsequent evaluation.
Qualitative evaluation: The evaluation uses objective data where possible (e.g. complaints and compliance history), but has been supplemented with qualitative information to ensure a more nuanced assessment.
Data limitations: Despite the limited data that has been available for the evaluation, the approach that has been adopted is to use available information to form a practical, high-level view of compliance culture, while acknowledging that the analysis can be deepened with more data in time to gain a more detailed understanding.

A structured framework to evaluate compliance culture has been used to overcome challenges

The framework used by the ARBV to evaluate compliance culture in the architecture sector comprises four main components, which are discussed below.

Profile of the sector

The first component involves gaining an understanding of the sector’s characteristics.
It includes consideration of the number and type of entities that participate in the sector, as well as the type and scale of the projects that they undertake, market dynamics, and risk landscape. This information provides essential context for evaluating compliance culture within the sector.

Compliance culture indicators

The second component involves identification of key indicators that reflect compliance culture.
These indicators are qualitative and quantitative measures that can be used to assess the compliance culture – that is, indicators that provide insights into the values, attitudes, and behaviour of sectoral participants that influence their approach to compliance with applicable regulatory obligations.
These indicators are intended to capture objective evidence of compliance culture (such as attendance at CPD seminars), as well as underlying drivers of compliance behaviour (such as particular types of construction procurement models or project types that affect compliance disposition and the incidence of non-compliance).

Data collection

The third component involves using the compliance culture indicators to gather relevant qualitative and quantitative data and other information so that assessment of compliance culture against the indicators can be undertaken.
Relevant data includes complaints and non-compliance statistics, insights and intelligence about non-compliant conduct from other regulators, and industry reports about market trends, pressures and vulnerabilities.
The data should ideally be obtained from multiple sources to minimise the risk of a biased evaluation of compliance culture and also to lay the foundation for a holistic assessment of the state of compliance culture across the sector.

Analysis and evaluation

The final component of the framework involves analysing the available data against the compliance culture indicators and interpreting the results in the context of the profile of the architecture sector.
More specifically, this involves identifying compliance weaknesses, while also considering external influences such as procurement practices, economic conditions and competitive pressures.

The evaluation framework enables the ARBV to form an evidence-based and nuanced view of compliance culture across the architecture sector

The evaluation framework outlined above is intended to enable the ARBV to develop an evidence-based and nuanced understanding of compliance culture, which will, in turn, allow regulatory activity to be strategically targeted so that the compliance culture within the architecture sector can be strengthened as a whole.
The following sections of this chapter apply the evaluation framework to the Victorian architecture sector.

D. Profile of the Australian architecture sector

Understanding the profile of a sector is essential when evaluating compliance culture because different sectors have unique operational structures, market dynamics, risks and compliance issues.
The particular features and characteristics of the Australian architecture sector reveal important insights about compliance culture and they may also affect the way in which compliance culture is evaluated.

In Victoria, the architecture sector consists mostly of sole practitioners and small firms

Local market structures and relative ease of entry have resulted in the proliferation of mostly small architectural firms with limited economies of scale.[50] The latest IBIS World report on Architectural Services in Australia (2024) suggests that the sector is heavily populated by smaller firms and individual practitioners owing to design work’s bespoke nature. The report states that each project requires significant customisation and personal attention, which is difficult to scale.[51]
At present in Victoria, there are currently, 5,675 registered practising architects, 1,525 approved companies and 27 approved partnerships.
In the 2024 annual survey undertaken by the ARBV of registered architects and approved companies and partnerships in Victoria, 1141 respondents answered as follows regarding the size of their practices:

Sole practitioners: 341 (30%)
0-5 staff: 555 (49%)
5-10 staff: 115 (10%)
10-25 staff: 71 (6%)
25 – 50 staff: 39 (3%)
50-100 staff: 14 (1%)
100+ staff: 6 (1%)

Across Australia, approximately 98% of architectural firms employ less than 20 people or do not employ anyone.[52] The largest four operators account for less than 10% of industry revenue.[53]

Sole practitioners and small firms may face unique challenges complying with their regulatory obligations

As the architecture sector is dominated by sole practitioners and small firms, the majority of sectoral participants may have limited resources to implement formal compliance frameworks.
Compliance risks can arise when a project is undertaken at a different scale than the architectural firm is accustomed to. Risks can also exist when a practice is involved in design for a different building typology from their usual type, or a different procurement method is used.
The predominance of sole practitioners and small firms in the architecture sector also affects how compliance culture can be evaluated. In particular, there may be fewer externally observable indicia of how compliance is managed by sole practitioners and small firms. In this setting, self-assessments and surveys may be the fairest and most accurate way to assess compliance culture, although these methods may also introduce some inherent bias into the evaluation that is difficult to account for.

Architects are likely to face significant competition in the current market context, which may also affect compliance culture

In Victoria, the barriers to entry to the market for provision of architectural services are relatively low. To practice as an architect, individuals must be registered with the ARBV, which requires completing an accredited architectural degree, gaining practical experience, and – for most practitioners – passing the Architectural Practice Examination (APE). Once registered, architects face minimal restrictions on setting up their practice, with no regulated limits on firm ownership or operational structure.
However, architects face competitive pressure from other building designers. These types of practitioners do not have the same educational background and qualifications as architects, are not regulated in the same way as architects, and are not held to the same professional standards. Nevertheless, building designers can perform similar services to architects (particularly architectural drafting) and typically charge lower fees because they are less regulated and may have lower insurance costs.
Architects also face increasing competition from vertically integrated firms, including large construction and engineering consulting firms. These large firms can offer clients integrated services at a lower price thanks to economies of scale.[54] Smaller architecture firms may not have the scale or brand recognition to compete for large projects.[55]

Competitive pressure may either serve to strengthen or undermine compliance culture, so an evidence-based and nuanced approach is needed when evaluating compliance culture

While the level of competition in the architecture sector is clearly relevant to the compliance culture within the sector, competitive pressure may either strengthen or undermine culture. This makes it difficult to know how to account for this factor in the evaluation of compliance culture.
On the one hand, strong competition can drive firms to maintain high compliance standards to differentiate themselves from other competitors, to build trust with clients, and avoid reputational damage if non-compliance were to occur. However, on the other hand, intense competition can also create pressure to cut costs, including costs that might otherwise be used to invest in compliance.
In light of this, an evidence-based and nuanced approach is needed when evaluating the impact of competitive pressure on compliance culture.

The culture, dynamics and practices within the broader construction sector may affect the compliance disposition and behaviour of architects

The broader construction sector's culture, dynamics, and practices are also likely to influence architects' behaviour, shaping their decision-making, collaboration styles, and professional priorities.
In Australia, the Design and Construct (D&C) procurement model is currently prevalent in the construction industry. Under this approach, a client engages a single contractor responsible for both the design and construction phases of a project. The centralisation of responsibility for design and construction is intended to streamline project delivery and foster early collaboration between designers and builders, potentially leading to cost savings and reduced timelines.
However, while D&C procurement can enhance efficiency in some areas, it may also prioritise cost and time considerations over quality and can result in compliance issues. When a client pushes for a very lean and fast design phase with early novation to the contractor, the project may reach the point of contractual agreement on time and cost before the design is appropriately developed for the stage. Once novated, the contractor may prioritise meeting their contractual obligations, often accelerating the documentation phase. This can put significant pressure on consultants, potentially compromising the quality and thoroughness of design development and coordination.
Understanding procurement practices, particularly the dominance of D&C in the Australian construction sector, is critical context for the evaluation of compliance culture in the architecture sector. It reveals how industry practices and contractual arrangements can undermine architects’ ability to uphold their professional duties. It also highlights the need for system-level solutions – not just individual accountability – when seeking to strengthen compliance.

E. Indicators of compliance culture

In order to evaluate compliance culture within the architecture sector, a range of qualitative and quantitative indicators are relevant at the individual, firm and sectoral levels.
This section sets out a suite of possible indicators that could be used to undertake the evaluation, while noting that there may be other indicators that could also provide helpful insights.
Even though the indicators are intended to facilitate evaluation of compliance culture by the ARBV, they could also be useful for architects, architectural firms, industry bodies and other participants in the broader construction sector for the same purpose.

The indicators of compliance culture are different at the individual, firm and sectoral levels

The indicators of compliance culture differ at the individual, firm, and sectoral levels because each level reflects different responsibilities, influences, and systemic factors that affect compliance behaviour.

Indicators of compliance culture at the individual/small firm level

The indicators set out below are intended to assess whether and how well individuals and small firms ensure that they comply with their obligations when undertaking their work:

Awareness of compliance obligations – to gauge whether individuals understand their responsibilities under the regulatory framework, particularly the Code of Professional Conduct.
Understanding and support for the rationale(s) underpinning compliance obligations – to gauge the level of alignment of individual values with the regulatory framework.
Participation in CPD – to measure engagement in ongoing education and efforts to stay up-to-date with requirements to comply with professional obligations.
Maintenance of clear and accurate records, particularly in relation to matters that are covered under the regulatory framework – to assess professionalism, discipline and transparency in professional practice.
Complaints and compliance history – to understand patterns of past issues with clients and non-compliance that may indicate cultural issues.
Willingness to report instances of non-compliance – to evaluate transparency and ethical courage and the prioritisation of professional integrity over the risk of regulatory action.
Willingness to co-operate with the regulator and proactively address non-compliance when it occurs – to assess accountability and willingness to improve.
Responsiveness to regulatory change – to identify proactive behaviour in staying informed about changes in the regulatory landscape.

Indicators of compliance culture at the larger firm level

The focus of the following indicators at the larger firm level is on how well a commitment to compliance is embedded in day-to-day operations and decisions across the firm’s operations:

Existence and enforcement of formal compliance policies and procedures – to determine whether structured compliance management frameworks are in place and whether they are actively enforced when non-compliance occurs.
Understanding and support for the rationale(s) underpinning compliance obligations – to gauge the level of alignment of the values of organisational leaders with the regulatory framework.
Integration of compliance into strategic documents and decision-making records– to assess how deeply compliance is embedded in leadership thinking, firm direction and decision-making practices.
Resources allocated to compliance, such as for compliance officers, compliance training and compliance guidance documents – to evaluate the priority given to compliance through resourcing and capacity-building.
Complaints and compliance history – to identify recurring compliance problems and evaluate responsiveness and learning from past incidents.
Willingness to report instances of non-compliance – to understand the internal culture of transparency and ethical responsibility.
Willingness to co-operate with the regulator and proactively address non-compliance when it occurs – to gauge the firm's approach to accountability and relationship with regulatory bodies.
Employee perception surveys on compliance culture – to capture lived experience of compliance culture from those operating within the firm day-to-day.

Sectoral level

As for the sectoral level, the indicators relate to factors that may affect the collective behaviour of firms within the architecture profession, which can be influenced by the nature and intensity of competition across the architecture sector as well as procurement practices and industry norms within the broader construction sector:

Economic conditions and market pressures that may affect compliance attitudes – to understand how external financial or commercial pressures may incentivise or discourage compliant behaviour, including procurement practices.
Engagement and collaboration with industry bodies about compliance – to assess the strength and effectiveness of sector-wide dialogue and shared responsibility for compliance.
Sector-wide compliance reviews, audits and benchmarking studies – to provide macro-level insights into how the sector is performing overall and where systemic weaknesses may exist.
Industry-wide adoption of best practices and ethical standards – to measure the proactive adoption of frameworks and practices that support a strong compliance culture beyond minimum requirements.
Public trust and reputation of the sector in relation to compliance – to understand the external perception of the sector’s professionalism, integrity, and regulatory accountability.

A collective analysis of indicators at the individual, firm and sectoral levels can provide a holistic picture of compliance culture

A consideration of indicators at the individual, firm, and sectoral levels provides a nuanced picture of compliance culture across the architecture sector, which highlights both micro-level behaviour and macro-level dynamics.
Individual-level indicators, such as employee attitudes and ethical behaviour, reveal how compliance values are understood and practised on the ground. Firm-level indicators, including governance structures, internal controls, and leadership commitment, show how these values are institutionalised and enforced within organisations. Sector-level indicators, such as industry practices and norms, reveal broader compliance attitudes and external influences shaping compliance behaviour.
Assessment of compliance culture at these three levels using distinct but interconnected indicators can enhance understanding of where strengths and weaknesses exist within the sector. This, in turn, enables any necessary regulatory interventions to be tailored accordingly.

F. Data to evaluate compliance culture

It is impossible to assemble data across all the key indicators identified above to comprehensively evaluate compliance culture within the Victorian architecture sector, as the cost and effort required to collect and analyse exhaustive information may outweigh the benefits.
Instead, this section of the report presents a snapshot of current compliance culture based on the best available information, while noting the limitations of the data and acknowledging that the analysis could be deepened in the future to gain a more detailed and nuanced understanding.
The following main sources of information have been used to establish a high-level view impression of compliance culture in the Victorian architecture sector:

Survey of regulated entities: A survey of entities that are regulated in Victoria by ARBV has been used to gather insights directly from a wide cross-section of members of the architecture profession. The survey questions are contained in Appendix B. They were designed to minimise burden on survey participants and to maximise the response rate. Five hundred and twenty three (523) entities responded to the survey. The survey was open for 1 week.
Focus group with key sectoral representatives: A focus group involving key sectoral representatives from Victoria has been used to obtain a deeper, qualitative understanding of compliance issues. The focus group enabled the ARBV to explore underlying drivers of compliance behaviour and provide context that may not be evident through the survey data alone. The focus group participants are listed in Appendix A and the questions discussed by the focus group are contained in Appendix B.
Complaints and compliance data: The insights from the survey and focus group have been complemented with available data about complaints made to the ARBV, including those that have led to regulatory action to address established non-compliance.

Together, these sources of information support a pragmatic yet balanced and credible assessment of compliance culture.

G. Evaluation of compliance culture in the Victorian architecture sector

The table below contains a summary of the evaluation of compliance culture in the Victorian architecture sector, based on the available data. Data was not available for all the indicators listed earlier in this chapter. Therefore, the table only covers indicators for which data was available.

SURVEY RESPONSES	FOCUS GROUP COMMENTS	EVALUATION
INDIVIDUAL LEVEL
Awareness of compliance obligations
The survey results suggest good awareness among respondents regarding their professional responsibilities, particularly compliance with the regulatory framework. 95% of respondents said they were very confident or somewhat confident that they understood their professional obligations. In addition, 94% associate professionalism with understanding and complying with the Code of Professional Conduct and all relevant laws. This tends to suggest that most practitioners are well-informed about the existence and content of their compliance obligations.	Focus group participants indicated that architects treat compliance as a core value, but suggested that there are limits in awareness and understanding of compliance obligations as illustrated by the following key points that were made. Recent graduates and students often see regulation as external to design, reflecting a gap in university education. Architects sometimes lack confidence in their regulatory knowledge, especially when dealing with contractors. Knowledge gaps exist, particularly around the NCC. Uncertainty was expressed about the profession’s knowledge and understanding of compliance obligations beyond the regulatory framework administered by the ARBV.	Awareness of compliance obligations is generally high, with most architects reporting confidence in their understanding of professional and legal responsibilities. However, this awareness may be uneven across the profession and in relation to certain aspects of compliance, including NCC compliance and legal obligations beyond the regulatory framework administered by the ARBV. This suggests a gap between perceived and actual understanding of compliance obligations within the profession, indicating the need for more targeted education, practical training, and ongoing professional development.
Understanding and support for the rationale(s) underpinning compliance obligations
The survey results indicate strong alignment between architect’s identification as a professional and the values that underpin compliance obligations in the regulatory framework. In responding to a question about what being a professional means in the context of architectural practice, 84% referred to maintaining clear ethical boundaries, 88% referred to ensuring quality and safety in building design, and 59% referred to acting in the public interest. These responses indicate that many practitioners understand and support the rationales underpinning the regulatory framework.	According to focus group participants, architects are generally committed to ethical, compliant solutions, even under pressure from cost or time limitations or builder-led substitutions. However, compliance can be undermined by contractual limitations, site exclusion during construction, and lack of authority to make decisions or influence outcomes in the context of D&C procurement.	Strong understanding and support for the rationale behind compliance is evident, with most architects linking professionalism to ethics, public interest, and ensuring safety and quality – these are core values that underpin compliance obligations in the regulatory framework. However, in practice, commitment to compliance may be challenged including but not solely in the context of D&C procurement, which can weaken architects’ ability to uphold these values, despite their strong professional commitment.
Participation in CPD
Audits of CPD compliance undertaken by ARBV indicate that there is room for improvement. In 2023, around 40% of those audited had not satisfactorily completed their CPD requirements. In 2024, this rose to 50%. Nevertheless, the survey results indicated that 89% of respondents are committed to maintaining skills and knowledge, which implies that professional development is widely valued, at least amongst those who responded to the survey.	Focus group participants did not comment on the rate of participation of architects in CPD. However, they expressed strong support for enhancing CPD, particularly in relation to the NCC. The following key points were made. CPD needs to be more targeted and competency-based, not just time-based. CPD should include case studies about real-world application of compliance requirements. CPD on NCC compliance should be mandatory.	While most architects value professional development, with 89% expressing commitment to maintaining skills and knowledge, actual CPD compliance is inconsistent, with non-compliance increasing from 40% (2023) to 50% (2024) in ARBV audits. Focus group participants support strengthening CPD, especially around the NCC, and advocate for more targeted, practical, and competency-based approaches.
Complaints and compliance history
This issue was not covered in the survey. However, the ARBV’s complaints and compliance data illustrates that there are ongoing compliance issues within the sector, particularly in relation to unprofessional conduct. In some of these cases, architects fail to turn their mind to compliance because they think compliance is the responsibility of another party. The ARBV has also encountered cases where architects assume that because the scope of their services is confined (e.g. providing partial or limited services) they are limiting risk and exposure to liability, when this is not necessarily as straightforward as they may think. Complaints about unprofessional conduct are consistent, making up around one-third to one-half of all complaints made to the ARBV each year. The number of complaints about unprofessional conduct has increased over the past 3 years: 2024-25: 59 complaints 2023–24: 49 complaints 2022–23: 26 complaints Based on these numbers, unprofessional conduct evidently remains a persistent issue.	Based on comments made by focus group participants, there are pockets of very compliant-minded architects within the profession. However, reference was made to instances of non-compliance that had been detected, particularly in relation to design documentation. It was suggested that compliance culture among architects for the design of Class 2 buildings is weak.	Unprofessional conduct remains a persistent concern, consistently making up a significant portion of complaints made to the ARBV each year, with an upward trend in recent years. Some focus group participants pointed to ongoing issues in design documentation for Class 2 buildings, which needs to be considered particularly in light of other complaints and compliance history data. There is evidence that, in certain circumstances, architects may fail to turn their mind to compliance as proactively as they should.
Willingness to report instances of non-compliance
This issue was not directly addressed in the survey.	Concern was expressed among focus group participants that architects may lack confidence or contractual authority to report non-compliance and resist directions from other construction sector participants that may lead to non-compliance. The point was also made that architects may feel disempowered to insist on compliance, especially when developers or builders have decision-making power under relevant contractual arrangements.	Architects may be reluctant or feel disempowered to report non-compliance, particularly when they lack contractual authority or confidence to challenge decisions made by more dominant parties in some project settings, like developers or builders. Contractual structures and power imbalances in the construction sector can limit architects' ability to insist on compliance or resist directions that could lead to non-compliance.
Responsiveness to regulatory change
The issue of responsiveness to regulatory change was not directly tested in the survey. However, survey respondents expressed a strong desire for simplified/clarified regulatory requirements (72%) and more practical training on compliance and risk management (48%). These responses suggest awareness of the complexity of regulatory requirements and a recognition of the need to keep up-to-date with them.	While architects were described as “ethical” and “trying hard to comply” by focus group participants, a number of participants indicated that regulatory complexity and the pace of change may make it challenging for architects to comply. However, the point was also made that there have been recent improvements in compliance within the profession following issuance of the Shergold-Weir report and the Lacrosse decision.	Architects are aware of the need to keep up-to-date with regulatory changes and have expressed a desire for clearer, more practical guidance and training. This indicates a willingness to respond to regulatory changes, but also suggests ongoing challenges to understand regulatory obligations. Regulatory complexity and the pace of change may be barriers to responsiveness to regulatory change, although recent developments (e.g. Shergold-Weir, Lacrosse) appear to have improved compliance awareness and responsiveness.
FIRM LEVEL
Existence and enforcement of formal compliance policies and procedures
Most survey respondents reported moderate to strong support from their firms regarding compliance with professional obligations, with over 70% rating support as Good, Very Good, or Excellent. However, 23% of respondents rated support as Fair or Poor, suggesting that in a notable minority of firms, formal compliance policies and procedures may be weak, underdeveloped, or inconsistently enforced.	This issue was not directly addressed in the focus group.	Most architects report strong support from their firms to comply with professional obligations. This suggests that formal compliance policies and procedures exist in many practices. However, the fact that nearly a quarter of survey respondents rated firm support as Fair or Poor indicates that a significant minority of firms may lack robust or consistently enforced compliance management systems. This points to inconsistencies across the profession, where firm support for compliance may depend heavily on individual firm culture and available resources.
Employee perception surveys on compliance culture
The relatively low percentage of survey respondents seeking more internal support from their firm regarding compliance (13%) suggests that most employees perceive their firm's compliance culture as generally supportive or, at least, not the principal barrier to professional conduct. However, the strong demand for external support – such as clearer regulation (72%) and practical training (48%) – indicates that employees do need more support to comply.	This issue was not directly addressed in the focus group.	Most employees view their firm’s compliance culture as generally supportive, with only a small proportion of survey respondents (13%) identifying more internal firm support as a major need to support compliance with professional obligations. The significant demand for external support, including clearer regulation and practical training, suggests that employees perceive systemic or regulatory complexity, rather than firm culture, as the main challenge to compliance.
SECTORAL LEVEL
Economic conditions and market pressures that may affect compliance attitudes
The survey responses reveal that commercial pressures from the broader construction sector are a major threat to compliance culture within the architecture profession. 78% strongly indicated that current practices in the construction sector can undermine architect’s ability to comply with their compliance obligations. In terms of the specific issues that can compromise architects’ ability to act professionally and comply with professional obligations, 71% referred to commercial pressures from clients or builders, 58% pointed to unrealistic project timelines, 47% referred to unclear roles and responsibilities, and 47% noted limited time or capacity to meet all obligations.	Focus group participants also suggested that practices within the broader construction sector may undermine compliance by architects. Contractual pressures can shift responsibility downward, with architects often expected to carry disproportionate compliance risk due to weak contractual standing and builder-driven project decisions. Time and resource constraints, such as last-minute review of shop drawings, may impair architects’ ability to meet compliance requirements. Consultant siloing can weaken coordination and undermine consistent compliance practices across teams. A lack of compliance oversight by building surveyors prior to certification, can lead to reactive rather than proactive compliance practices, increasing the risk of non-compliance in later stages of a project.	Commercial and contractual pressures from clients and builders are a significant factor undermining compliance culture within the architecture profession, with many architects reporting weakened capacity to meet compliance obligations due to unrealistic timelines, shifting responsibilities, and builder-led decisions. Structural issues in the construction sector including weak authority for architects under contractual arrangements, poor coordination among consultants, and late-stage compliance checks create an environment where economic and market pressures consistently undermine compliance.
Public trust and reputation of the sector in relation to compliance matters
This issue was not addressed in the survey.	Focus group participants noted that architects are viewed as ethical and professional, but their reputation is at risk because they may be targeted in litigation to access their professional indemnity insurance.	Architects are generally regarded as ethical professionals with strong compliance values, supported by robust regulation, professional accountability, and higher standards than many others in the construction sector. This underpins a relatively high level of public trust in the profession. However, gaps in regulatory understanding, limited on-site authority, and systemic issues in the broader construction sector can undermine the effectiveness of architects' compliance efforts and expose them to disproportionate blame, posing risks to public confidence in the sector.

Overall evaluation of compliance culture at the individual level

Based on the available data, architects demonstrate a clear commitment to compliance, reflecting an understanding of their professional responsibility to uphold high standards. However, this commitment may be challenged by project realities and complexities, such as D&C procurement and the lack of power to influence compliance decisions that could arise in this context.
While CPD is broadly valued within the architecture profession, inconsistent compliance with CPD requirements signals a gap between intent and practice. Given their professional status, architects must take personal responsibility for maintaining their competence. The data indicates a need for more practical training, especially on compliance with the NCC.
A strong compliance culture requires architects to act with honesty, integrity and courage. Yet, the data indicates that fear of conflict or lack of authority can prevent architects from reporting or resisting non-compliance in certain procurement contexts.
Despite the challenging and complex environment in which some architects operate, there is evidence that architects may fail to turn their mind to compliance, particularly if they believe that the primary responsibility for doing so rests elsewhere or that their responsibility for compliance is confined (e.g. because they are providing partial services).
The available evidence indicates that members of the profession are willing to learn and improve, consistent with a professional mindset. However, the complexity of regulatory requirements and the pace of change may make it difficult for architects to maintain individual compliance and competence.

Overall evaluation of compliance culture at the firm level

The data indicates that most firms are seen as supportive of compliance. However, a significant minority are viewed as not providing enough support to ensure that architects comply with their obligations. As architects are held to high standards and expected to proactively engage with compliance, it is essential that firms create environments that enable and reinforce this professional responsibility.
Nevertheless, the available evidence indicates that internal firm support is not seen as a major barrier to compliance. The greater challenge to compliance with professional obligations appears to come from outside firms, particularly regulatory complexity and commercial pressure from clients and builders. Architects may need more support from their firms to equip them to navigate these challenges, while maintaining a proactive, and committed approach to compliance at the individual level.

Overall evaluation of compliance culture at the sectoral level

While architects are held to high professional standards and expected to take a proactive approach to compliance, sectoral dynamics can create structural barriers that make this difficult to sustain in practice. In particular, evidence from various sources indicates that commercial and contractual pressures in the broader construction sector may undermine architects’ ability to comply with their obligations, particularly due to tight timelines, shifting responsibilities, and builder-led decisions.
Despite these challenges, architects are widely regarded as ethical and professionally accountable, reflecting a strong professional identity.
However, practices within the broader construction sector may expose them to disproportionate blame, posing risks to public confidence in the broader sector. This not only undermines the standing of individual professionals that are affected by these practices, but also risks eroding public confidence in the construction sector as a whole.

H. Concluding remarks

The evaluation of compliance culture in the architecture sector highlights the complex and challenging circumstances in which architects are expected to uphold their professional obligations.
There is clear evidence of individual commitment to compliance within the profession, consistent with a professional mindset. However, this commitment may be tested by systemic pressures – particularly, those arising from procurement models, contractual arrangements, and regulatory complexity.
Practices within the broader construction sector – including the erosion of architects’ authority, unrealistic commercial expectations, and poor coordination among consultants – may undermine architect’s capacity to uphold their professional standards and maintain compliance in practice. Individual architects and architectural firms may have limited influence in changing these practices.
Despite this, architects continue to be perceived as ethical professionals committed to public safety, quality, and accountability, which are core aspects of their professional identity. However, maintaining public trust depends on strengthening sector-wide practices and conditions that are needed to support compliance, including improving regulatory clarity and addressing power imbalances that could challenge professional conduct within the broader construction sector.
Noting these challenges, the next chapter identifies the strategies for architects to strengthen compliance culture.

[50] McKinsey & Company, The next normal in construction: How disruption is reshaping the world’s largest ecosystem (2020), at p. 5.

[51] IBIS World, Architectural Services in Australia M6921 (2024), at p.19.

[52] Ibid. at p.16.

[53] Ibid.

[54] Ibid. at p. 4.

[55] Ibid.

Updated 30 July 2025