The U.S. Department of Education is proposing a significantly narrower definition of professional degrees for federal student loan purposes, and architecture programs have been excluded from the proposed professional degree list. This change could dramatically impact graduate architecture students' access to federal funding, potentially limiting their borrowing capacity by half starting in July 2026.
Under the proposed regulations, the federal definition will determine which graduate programs qualify for higher professional program loan caps beginning July 1, 2026. If architecture remains excluded from the professional degree classification, many Master of Architecture (M.Arch) and other graduate architecture students could face substantially lower federal borrowing limits, capped at $100,000 instead of the $200,000 available to recognized professional programs.
The proposal has completed its negotiated rulemaking process in November 2025 and will be opened for public comment in early 2026. The final definitions and program lists emerging from this process will determine the real-world financial impact on architecture students nationwide.
For practicing architects and professionals in the field, state licensure requirements will remain unchanged. NAAB-accredited Bachelor of Architecture (B.Arch), Master of Architecture (M.Arch), and Doctor of Architecture (D.Arch) degrees will continue to be recognized as professional degrees for licensing purposes. However, the primary concern centers on the education-to-workforce pipeline, as rising costs or declining enrollment could create long-term challenges for the profession.
Architecture firms may face recruitment and retention pressures if prospective students require additional private financing or choose to delay their graduate studies due to financial constraints. The reduced federal loan availability could make architecture education less accessible to students from diverse economic backgrounds.
For current and prospective architecture students, NAAB-accredited degrees will still qualify for professional licensure, but the federal financial aid treatment may change significantly if the proposal is finalized. Students may need to seek alternative funding sources or take on higher-interest private loans to cover educational expenses.
The American Institute of Architects (AIA) is actively responding to this development through multiple channels. The organization is requesting formal clarification from the Department of Education regarding architecture's omission and the intended impacts of this exclusion. AIA is also coordinating with partner organizations across education and licensure sectors to present a unified response and is preparing comprehensive comments and policy options to restore recognition of architecture as a professional degree for federal aid purposes.
The AIA is encouraging members and stakeholders to participate in the upcoming formal comment period, expected in early 2026. The organization's Government Affairs division is also advocating for Congress to take a more comprehensive approach to the student loan cap issue, recognizing that legislative action may be necessary to address these concerns effectively.
The proposed professional degree list represents a dramatic reduction in coverage, shrinking from thousands of programs to a small set of fields while excluding many disciplines that lead to licensure-based professions. Architecture joins numerous other professional fields that have been excluded from the current proposal.
Under the new federal law taking effect July 1, 2026, the current Grad PLUS loan program will end and be replaced with hard borrowing caps. Graduate programs not classified as professional will be limited to $20,500 per year and $100,000 lifetime in federal loans, while programs designated as professional can access up to $50,000 per year and $200,000 lifetime. Undergraduate federal loan limits for bachelor's degree students will remain unchanged, with caps set annually by year in school.
The exclusion of architecture is particularly significant because programs not listed as professional will be treated as standard graduate programs for borrowing purposes. This means architecture graduate students could be relegated to the lower borrowing tier despite the fact that architecture degrees are considered professional credentials for licensure and practice. The potential impact extends beyond individual students to affect the broader architecture profession's ability to attract diverse talent and maintain educational standards.
