Illegal Practice and Act Enforcement

One of the ways the Architects Act (the Act) protects the public is by restricting the practice of architecture in Ontario to individuals and practices authorized by the Ontario Association of Architects (OAA). These requirements ensure that architectural services are provided only by licensed professionals operating within a regulated framework. That framework includes oversight, professional and practice standards, insurance requirements, and discipline processes.

Practice of Architecture

Under the Act, the practice of architecture is defined as:

the preparation or provision of a design to govern the construction, enlargement, or alteration of a building;
evaluating, advising on, or reporting on the construction, enlargement, or alteration of a building; or
a general review of the construction, enlargement, or alteration of a building.

These services may be provided at any stage of a building’s lifecycle, including planning, design, construction, occupancy, and post-occupancy phases.

In Ontario, architectural services may only be provided to the public through an OAA certificate of practice (CoP). A CoP can held by an individual, partnership, or corporation authorized to offer and provide architectural services to the public.

Even when an individual is an OAA member, architectural services may only be offered to the public through an OAA CoP. Membership in the OAA alone does not authorize independent offering of services to the public.

Illegal Practice of Architecture

Illegal practice occurs when a person or organization provides, offers to provide, or undertakes architectural services without being authorized under the Act, including where the required CoP has not been obtained.

Illegal practice may include work such as designing buildings, advising on construction, conducting building assessments, or reviewing construction where those services fall within the protected scope and are not carried out under an OAA CoP.

Protected Titles and Holding Out

Under the Act, it is an offence for an unlicensed person (including a corporation) to use the term “Architect” or "Licensed Technologist" or any derivative. It is also an offence to hold oneself out as engaging in the practice of architecture without a licence or limited licence issued by the OAA.

Misrepresentation of the protected title “Architect” or "Licensed Technologist" and misleading claims or advertising (inadvertently or purposely) could lead the public to conclude they would be receiving architectural services from a regulated professional.

Misuse of protected titles, or representing oneself as entitled to engage in the practice of architecture in Ontario when not authorized to do so, is commonly referred to as “holding out.” Holding out may be an indicator of illegal practice, particularly where it is accompanied by the offering or provision of architectural services.

How the OAA Protects the Public

The OAA is responsible for enforcing the Act. This includes addressing instances of unauthorized practice, misuse of protected titles, and other contraventions of the Act.

Enforcement action may be taken where individuals or firms provide, offer, or advertise architectural services to the public without the required certificate of practice, or otherwise in contravention of the Act.

When a potential breach is identified, the OAA may:

investigate the matter;
contact the individual or organization to seek compliance;
require that unauthorized activity cease;
pursue legal remedies where necessary, including court injunctions; and/or
prosecute offences under the Act

In many cases, concerns are resolved through early engagement and voluntary steps taken following communications with the OAA. However, where necessary, the OAA takes formal enforcement action to protect the public interest.

Why Act Enforcement Matters

Architectural services directly impact public safety, accessibility, environmental performance, and the long-term quality of the built environment. The regulatory framework ensures that individuals and organizations providing these services are accountable to professional standards and operate within a system of oversight.

Members of the public are encouraged to verify that both the individual and the organization offering architectural services are authorized by the OAA, particularly when engaging professionals for building design or related advisory services.

This page answers Frequently Asked Questions about illegal practice and act enforcement from the perspective of both OAA members and the public. To learn more about the OAA’s enforcement actions in 2025, click here.

What is the OAA’s role in enforcing the Architects Act?

Under the Act, the OAA is tasked with ensuring:

projects requiring an Architect or projects requiring a Licensed Technologist have an OAA member engaged who is responsible for the design of the project—to this end, the Association works regularly with its members, professional engineers, planners, building officials, and owners to assist in determining when this is true for a project or a project stage (e.g. a formal application to a local government);
only those who are appropriately trained, qualified, and licensed with the OAA use the occupational designation of “Architect" and only those who are appropriately trained, qualified, and issued a limited licence with the OAA use the title "Licensed Technologist;" and
only through a certificate of practice (CoP) can architectural services be offered or provided to the public. (CoPs are listed in the OAA Directory).

The OAA’s regulatory mandate includes taking action against those unlawfully providing or offering to provide architectural services. The Architects Act and its Regulations outline specific exceptions, but outside of these, the OAA may take legal action to prevent unlawful practice or unlawful holding out. In most cases where illegal practice is identified, the OAA will contact the project’s owner and advise the Authority Having Jurisdiction (AHJ) that permits should not be issued to projects proceeding illegally.

What is the process of Act enforcement? How do members of the OAA or members of the public take action?

Anyone can report a potential breach of the Architects Act. Members of the OAA are required to report unauthorized practice—failure to do so could result in a finding of professional misconduct. If you are aware of a possible infraction:

1. Inquire whether the individual or practice is registered with the Association by searching the OAA Directory. In most cases, if the individual or practice is not listed, it is not regulated by the OAA. However, the OAA issues temporary licences to out-of-province architects who work on specific projects in collaboration with OAA members. Temporary licence holders are not listed in the directory. Please contact enforcement@oaa.on.ca if you have specific questions.

2. Collect as much information and documentation as possible. Photographs of a project sign, copies of permit applications, business cards, title blocks, articles, advertisements, webpages, relevant correspondence, and drawings can be useful. Include contact information for the alleged contravener, if possible.

3. Submit the collected information. You can email enforcement@oaa.on.ca or mail the package to:

Act Enforcement
Ontario Association of Architects
111 Moatfield Drive
Toronto, ON
M3B 3L6

The OAA will investigate when a possible infraction is brought to its attention.

Please note: OAA staff members are prohibited from providing any updates or information about complaints relating to the breach of the Architects Act. Once the information has been received, all persons engaged in the administration of the Act are required to preserve the confidentiality of all matters relating thereto.

What actions does the OAA take if it appears as if illegal practice has taken place?

Where the OAA determines that illegal practice or non-compliance with the Architects Act may have occurred, it may take a range of actions depending on the circumstances. This includes:

sending an inquiry letter advising of the concerns, and requesting specific corrective action (this is a common first step in the case of misrepresentations);
requesting the individual sign an undertaking, which includes an acknowledgment of the Act breach and agreement to compliance in the future; and/or
pursuing injunctive relief or a prosecution in court.

What happens in cases where there is a breach of the Act? How many instances happened this year?

While confidentiality is maintained about individual instances of Act enforcement, the OAA releases aggregated information. The graphic below summarizes the OAA’s enforcement activities for 2025.

There were 111 investigations in 2025—a number that includes both new matters as well as active ongoing investigations. Of these, 85 were resolved by the Office of the Registrar (i.e. no further action was required due to the OAA’s enforcement hierarchy matrix, that there was no breach, or changes were implemented). As of January 2026, there are 25 that remain ongoing.

Can I use the word “architectural” in my title or use "architecture" to describe the work I do if I am not licensed with the OAA?

The Architects Act expressly prohibits those who do not hold a licence with the OAA from using an addition to or an abbreviation of the title “Architect,” an occupational designation, or a term, title, addition, or description that will lead to the belief the person may engage in the practice of architecture. Similarly, the Act limits the use of the title “Licensed Technologist” to individuals issued a limited licence by the OAA.

Read broadly, it would be prudent for individuals working in the building and construction industry to refrain from using titles that includes the word "architectural" or similar derivatives, or to use the word "architecture" when describing services, to avoid confusing the public.

Where the OAA believes a job title or description of services could be viewed as misleading to the public, it may take regulatory action against the company or individual.

I’m a foreign trained architect, but not yet licensed by the OAA. Can I call myself an architect?

No. You are not permitted to use the title ‘Architect’ in Ontario if you are not licensed by the OAA. You are permitted to list your credentials and indicate the jurisdictions where you are currently authorized to practise architecture—however, if you choose to do so, you must make it clear you are not a licensed Architect in Ontario.

If you are registered as an Intern Architect, review the OAA Memorandum, Use of the Title ‘Intern Architect.’

Can a business that does not hold a Certificate of Practice state that it offers architectural services?

No. Only individuals and firms that hold an OAA CoP are authorized to offer or provide architectural services to the public in Ontario.

A CoP is required whether architectural services are provided by an individual, partnership, or corporation.

Businesses that do not hold a CoP must not describe, present, or advertise their services in a way that suggests they are authorized to provide architectural services under the Architects Act.

Where companies coordinate work with OAA members, they must ensure that the architectural services are clearly identified as being provided by an authorized OAA practice.

Misrepresentation or holding out as providing architectural services without authorization under the Act may result in legal action by the OAA.

Engineering, consulting, and project management firms may work with OAA members in the delivery of projects. However, they must ensure that their marketing, communications, and service descriptions do not imply that they are authorized to provide architectural services in Ontario unless they hold an OAA CoP.

The use of terms such as “architectural services” or “architecture practice” should be limited to OAA members and practices authorized through a certificate of practice. Appropriate alternative descriptions may include “design services,” “drafting services,” or “design/build services,” where accurate.