糖心vlog

December 11, 2025

Legislative Impacts to Architectural Education in the U.S.

PROFESSIONAL DEGREES & STUDENT LOANS

糖心vlog Fact Sheet: Proposed Changes Impacting Architectural Education

Washington D.C., December 11, 2025

Graduate students in architecture at U.S. universities face new limits on the amount of federal student loans they can access as a result of proposed policy changes related to the federal . While these changes do not jeopardize architecture鈥檚 status as a licensed profession, 糖心vlog is extremely concerned about the effects that the U.S. Department of Education鈥檚 (ED) interpretation of the law will have on architectural education and practice. Proposed outcomes impacting architectural education are listed below.

Topic #1: Graduate Loans Face New Limits听听听

New rules fixing the list of professional degrees and excluding architecture from it will cap loans available to students in both professional and post-professional graduate architecture programs but the impact to loan limits is not extreme. Currently, architecture students are not classified as 鈥減rofessional students鈥 by the Department of Education (ED). Prior to mandatory definition changes in 2011, the M.Arch and the D.Arch were commonly understood to be first-professional degrees within the academy and architectural practice but this was never articulated by the Department of Education. The data collection system for the Department of Education uses the following definition for 鈥淒octor’s degree-professional practice鈥:

鈥淎 doctor’s degree that is conferred upon completion of a program providing the knowledge and skills for the recognition, credential, or license required for professional practice. The degree is awarded after a period of study such that the total time to the degree, including both pre-professional and professional preparation, equals at least six full-time equivalent academic years. Some of these degrees were formerly classified as first-professional and may include: Chiropractic (D.C. or D.C.M.); Dentistry (D.D.S. or D.M.D.); Law (J.D.); Medicine (M.D.); Optometry (O.D.); Osteopathic Medicine (D.O); Pharmacy (Pharm.D.); Podiatry (D.P.M., Pod.D., D.P.); or, Veterinary Medicine (D.V.M.), and others, as designated by the awarding institution.鈥

offers the following definition for 鈥済raduate or professional student.鈥

  • Graduate or professional student:
    • A student who鈥
      • (1) Is not receiving title IV aid as an undergraduate student for the same period of enrollment;
      • (2) Is enrolled in a program or course above the baccalaureate level or is enrolled in a program leading to a professional degree; and
      • (3) Has completed the equivalent of at least three years of full-time study either prior to entrance into the program or as part of the program itself.

And the following definition for a professional degree:

  • Professional degree: A degree that signifies both completion of the academic requirements for beginning practice in a given profession and a level of professional skill beyond that normally required for a bachelor’s degree. Professional licensure is also generally required. Examples of a professional degree include but are not limited to Pharmacy (Pharm.D.), Dentistry (D.D.S. or D.M.D.), Veterinary Medicine (D.V.M.), Chiropractic (D.C. or D.C.M.), Law (L.L.B. or J.D.), Medicine (M.D.), Optometry (O.D.), Osteopathic Medicine (D.O.), Podiatry (D.P.M., D.P., or Pod.D.), and Theology (M.Div., or M.H.L.).

The Bachelor of Architecture (B.Arch.), Master of Architecture (M.Arch.), and Doctor of Architecture (D.Arch.) would fit squarely within this definition. Four-year bachelor degrees in architecture and architectural studies as well as post-professional master and doctoral degrees would not be included in this definition.

Student Program TypeMaximum Annual Federal Direct Loan AmountMaximum Aggregate Federal Direct Loan Amount听
Graduate or Professional Student

(All graduate arch programs)

$20,500 (unsubsidized only)$138,500 (Including any federal loans received for undergraduate study.)
Between $33,000 and $47,167 depending on the discipline$224,000 (Including any federal loans received for undergraduate study.)
Graduate Student$20,500 (unsubsidized only)$100,000 (Excluding any federal loans received for undergraduate study.)
Professional Student$50,000 (unsubsidized only)$200,000 (Excluding any federal loans received for undergraduate study.)

As shown above, there are higher annual Direct Unsubsidized Loan limits for . The increased unsubsidized amounts that an eligible health professions student may receive are in addition to the regular $20,500 Direct Unsubsidized Loan annual loan limit for graduate and professional students. Graduate and professional students who qualify for the higher annual Direct Unsubsidized Loan limits are also eligible for a higher combined subsidized/unsubsidized aggregate loan limit, as shown above.

Changes from the OBBBA:

New regulations narrow the definition of a 鈥済raduate student鈥 and a 鈥減rofessional student.鈥 The OBBBA caps the annual loan limits at $20,500 for graduate students and $50,000 for professional students. Additionally, the aggregate limit is capped at $100,000 for graduate students and $200,000 for professional students, but does not include amounts borrowed as an undergraduate. Last month, outcomes from the negotiated rulemaking committee, (RISE), further the disciplines included by revamping the language to remove the clause 鈥渋ncluding but not limited to鈥 and adding Clinical Psychology, and other programs sharing the same four-digit CIP code to the list. The aim of the committee was to be finite and comprehensive in its new listing.

鈥淎 professional degree may be awarded in the following fields: (i) Pharmacy (Pharm.D.), Dentistry (D.D.S. or D.M.D.), Veterinary Medicine (D.V.M.), Chiropractic (D.C. or D.C.M.), Law (L.L.B. or J.D.), Medicine (M.D.), Optometry (O.D.), Osteopathic Medicine (D.O.), Podiatry (D.P.M., D.P., or Pod.D.), Theology (M.Div., or M.H.L.), and Clinical Psychology (Psy.D. or Ph.D.).鈥

Impact on Architectural Education:

According to NAAB 2024 reporting, 68% of professional architecture programs offer the Master of Architecture (M.Arch.) and less than one percent offer the Doctor of Architecture (D.Arch.). These degrees account for approximately 14,267 students. Under the proposed guidelines the Bachelor of Architecture (B.Arch.), Master of Architecture (M.Arch.), and Doctor of Architecture (D.Arch.) would not fit within this definition. Both NAAB-accredited and non-NAAB-accredited graduate students in architecture were previously eligible for the aggregate federal student loan limit of $138,500 for graduate or professional students. The annual loan limit has remained the same ($20,500 per academic year) but the aggregate amount has been capped at $100,000 not including undergraduate loans as opposed to $138,500 including loans received for undergraduate study.

Topic #2: Elimination of Graduate PLUS Loan Program

Currently, there are no fixed annual loan limits for Direct PLUS Loans. A graduate or professional student may be awarded a Graduate PLUS Loan for up to the student鈥檚 cost of attendance (COA) minus other financial assistance (OFA). These loans are intended to fill in the gap between what a graduate or professional student can pay, the federal student loans they can borrow, and the total cost of attendance, which includes items like room and board, books and supplies, and student health plans. For instance, if the total cost of attendance for an Master of Architecture (M.Arch) program totals $29,500 per year, a student may be eligible for $20,500 in Direct Unsubsidized Loans and an additional $9,000 per year in Graduate PLUS Loans in order to meet their needs to live, work, and study in that M.Arch program.

Changes from the OBBBA:

Graduate PLUS loans are eliminated effective July 1, 2026.

Impact on Architectural Education:听

This is the most significant change impacting architectural education. If Graduate PLUS loans are no longer offered, students will need to find alternative ways to meet the gap between the federal student loans they are eligible for and the total cost of attendance when the total cost of attendance is greater than $20,500. This gap is often exacerbated when incoming students are relocating from places with a lower cost of living, e.g. the American South, to places with higher cost of living, e.g. the New England states or California. (Note: There is a legacy provision for current students.)

Topic #3: Undergraduate Loan Limits Largely Unchanged

For Direct Subsidized Loans and Direct Unsubsidized Loans, there are limits on the amount undergraduate students can borrow each academic year (annual loan limits) and the total amounts they can borrow for undergraduate and graduate study (aggregate loan limits). Annual loan limits vary depending on a student鈥檚 year in school and whether they鈥檙e a dependent or independent student (dependency status). The actual loan amount they鈥檙e eligible to receive each academic year may be less than the annual loan limit.

The maximum combined amount of Direct Subsidized and Direct Unsubsidized Loans an undergraduate student can borrow each academic year is between $5,500 and $12,500, depending on their year in school and dependency status.

Changes from the OBBBA:

The OBBBA limits the annual and aggregate loan limits of Parent PLUS loans, allows institutions to impose lower course of study loan limits, and creates an institutional accountability metric based on the earnings of recent grads compared to working adults without a college degree but this has yet to be fully articulated. All things considered, there are no substantial changes impacting undergraduate students’ borrowing limits.

Impact on Architectural Education:

According to NAAB 2024 reporting, 32% of professional architecture programs offer the Bachelor of Architecture (B.Arch.). This degree accounts for more than 19,000 students. Moreover, 糖心vlog data projects more than 21,000 students are enrolled in four-year architecture programs not accredited by NAAB, such as the B.S./B.A. in Architecture or Architectural Studies or the Bachelor of Environmental Design. What could potentially be of concern is the 鈥渓ow earning outcomes鈥 measure if the B.Arch and the non-accredited programs do not have a high enough earnings to remain eligible for federal student loans.

About the Association of Collegiate Schools in Architecture (糖心vlog)
The mission of the Association of Collegiate Schools of Architecture is to lead architectural education and research. Founded in 1912 by 10 charter members, 糖心vlog is an international association of architecture schools preparing future architects, designers, and change agents. 糖心vlog鈥檚 full members include all of the accredited professional degree programs in the United States and Canada, as well as international schools and 2- and 4-year programs. Together, 糖心vlog schools represent 7,000 faculty educating more than 40,000 students.

糖心vlog seeks to empower faculty and schools to educate increasingly diverse students, expand disciplinary impacts, and create knowledge for the advancement of architecture. For more information, visit www.acsa-arch.org.

Kendall A. Nicholson
Senior Director of Research, Equity, and Education
202-785-2324
knicholson@acsa-arch.org