Federal "Professional Degree" Definition Excludes Architecture — Member Briefing
The Department of Education is proposing a much narrower definition of “professional degrees” for federal student-loan purposes, and architecture is not included on the proposed professional-degree list.
What’s happening: The Department of Education is proposing a much narrower definition of “professional degrees” for federal student-loan purposes, and architecture is not included on the proposed professional-degree list.
Why it matters: The federal definition will control which graduate programs qualify for higher “professional program” loan caps starting July 1, 2026. If architecture remains excluded, many M.Arch and other graduate architecture students could face lower federal borrowing limits ($100,000 vs $200,000).
What’s next: The proposal finalized its negotiated rulemaking process in November and will be put out for public comment in early 2026; final definitions and program lists will determine the real-world impact.
What it means for you
- Architects / practitioners
State licensure requirements do not change; NAAB-accredited B.Arch/M.Arch/D.Arch remain professional degrees for licensing. The main risk is the education-to-workforce pipeline if costs rise or enrollment drops. - Firms
Potential recruitment and retention pressure if students need more private financing or delay graduate study. - Students / emerging professionals
Your NAAB-accredited degree still counts for licensure, but federal aid treatment may change if the proposal is finalized.
What AIA is doing
• Requesting formal clarification from ED on architecture’s omission and intended impacts.
• Coordinating with partner organizations across education and licensure to present a unified response.
• Preparing comments and policy options to restore recognition of architecture as a professional degree for federal aid purposes.
What you can do
• There will be a formal comment period on this rule some time early in 2026. Keep your eyes peeled for an email from AIA Government Affairs asking for you to submit comment.
• While this rule is proposed by the Department of Education, Government Affairs is advocating that Congress take a more comprehensive approach to the student loan cap issue. We'll be reaching out to you in the coming weeks to write your member of Congress about this, as well.
• Tell your colleagues and friends that this is happening. Share with your network within the architect community, but also more broadly on social media. This rule affects a vast array of professionals, and many may not have heard about this issue yet. Share this page on social media!
Additional Background
The proposed professional-degree list reduces coverage from thousands of programs to a small set of fields, excluding many disciplines that lead to licensure-based professions. Architecture is among the excluded fields in the current proposal.
- Undergraduate loans: Federal Direct Loan limits for bachelor’s students stay the same: caps are set annually by year in school and remain relatively low compared with graduate borrowing.
- Graduate loans starting July 1, 2026: A new federal law ends Grad PLUS and replaces it with hard borrowing caps.
- Graduate programs (non-professional): up to $20,500 per year and $100,000 lifetime in federal loans.
- Professional programs (as ED defines them): up to $50,000 per year and $200,000 lifetime.
- Why architecture’s exclusion is consequential: Programs not listed as “professional” are treated as standard graduate programs for these caps—so architecture graduate students could be limited to the lower borrowing tier even though architecture degrees are professional for licensure.
Firms expect modest revenue declines in 2025 and 2026.
