October 27, 2025
To: Global Affairs Canada
Trade Negotiations- North America via
email: CUSMA-Consultations-ACEUM@international.gc.ca
From: Royal Architectural Institute of Canada (RAIC)
Re: Submission on the Operation of CUSMA and its Impact on Architecture
Executive Summary
CUSMA exists to enhance trade and professional mobility across North America by reducing barriers, ensuring transparency, and fostering cooperation. For architecture, this includes enabling cross-border professional services, supporting fair and transparent procurement, and aligning with shared continental priorities such as sustainability, innovation, and inclusive growth.
The RAIC recommends that Canada work with its CUSMA partners to:
1. Strengthen Professional Mobility: Recognize and promote the updated Tri-National Mutual Recognition Agreement (MRA).
2. Advance Fair Procurement: Encourage adoption of quality-based selection (QBS) and fair fee practices.
3. Integrate Climate Action: Use CUSMA’s environment and cooperation frameworks to promote building decarbonization and resilience.
4. Support Inclusive Trade: Reduce compliance burdens for small and medium-sized enterprises (SMEs) and support under-represented practitioners.
5. Uphold Indigenous Rights: Protect Indigenous procurement and design leadership under treaty provisions.
These recommendations support the core objectives of CUSMA: reducing barriers to trade in services, facilitating transparent and fair competition, and strengthening cooperation among the three countries.
CUSMA’s success in the architectural sector should not be measured solely by market access, but by how it supports design excellence and a culture of design across the built environment in all three countries. By promoting fair procurement and reciprocal mobility, the agreement can enhance innovation, cultural expression, and design quality, strengthening a North American culture of design that benefits communities and economies alike.
1. Professional Mobility and the Tri-National MRA
The 2024 Tri-National MRA between Canada, Mexico, and the U.S. modernizes reciprocal licensure by reducing the required post-licensure experience from ten years to five, removing citizenship restrictions, and expanding eligibility to include architects who earned licensure through alternative pathways. This expanded eligibility allows more architects to benefit from reciprocal recognition while maintaining public protection standards common to all three jurisdictions. It operationalizes CUSMA’s Chapter 15 provisions on professional services and Annex 15-C.
Recommendation:
CUSMA’s procurement chapter does not apply to Canada–U.S. trade (which is covered under the WTO Government Procurement Agreement), it provides a valuable forum for cooperation and sharing of best practices.
Quality-Based Selection (QBS) ensures fair competition, design excellence, and lifecycle value. This aligns with CUSMA’s goal of transparent and efficient trade in services. QBS is both a transparent and fiscally responsible method of procurement. By prioritizing quality and competence in selection, public authorities enable consultants to define appropriate scope and design solutions early in the process, resulting in fewer change orders, fewer delays, and reduced construction risk. Investing appropriately in design and documentation phases consistently saves significant hard costs, delivering better project performance, higher value, and stronger design outcomes.
CUSMA can reinforce these shared standards of excellence by encouraging their adoption across all three nations. Embedding QBS principles within CUSMA cooperation would demonstrate Canada’s leadership in advancing both fiscal responsibility and design quality across North America.
Recommendation:
CUSMA’s environment chapter strengthens cooperation but does not explicitly reference climate change. Buildings and infrastructure are central to North American trade, competitiveness, and sustainability. Integrating environmental performance with design quality ensures that climate action in the built environment also strengthens cultural identity, livability, and architectural innovation across North America.
Recommendation:
Create a trilateral cooperation stream on low-carbon, resilient buildings.
Integrate life-cycle performance criteria into procurement under CUSMA cooperation forums.
Demonstrate a shared global ambition for climate leadership while empowering local innovation to achieve it.
4. Inclusive Trade and SME Access CUSMA emphasizes SME participation and reducing barriers. In architecture, SMEs and under-represented firms face disproportionate compliance burdens.
Recommendation:
Article 32.5 and Canada’s Annex II reservations safeguard Indigenous rights and procurement preferences. Architecture plays a key role in Indigenous procurement and design leadership. Indigenous-led architectural practices exemplify design excellence rooted in cultural knowledge and stewardship, demonstrating how reconciliation contributes to a more holistic and sustainable North American design culture. These measures align with CUSMA’s objectives of fair competition and inclusive trade while recognizing the unique rights and contributions of Indigenous peoples.
Recommendation:
Recommendation:
About the RAIC
The Royal Architectural Institute of Canada (RAIC) is a not-for-profit, national organization dedicated to representing architects and architecture since 1907. The RAIC is the only national voice for excellence in the built environment in Canada focused on providing Canada’s architects and architectural community with the tools, resources, and education to elevate their practice. The RAIC is committed to showcasing how design enhances quality of life, while advocating for important issues of society through responsible architecture. The RAIC’s mission is to build a better world for all by empowering a strong culture of design excellence in Canada. Through its work, the organization's vision is to establish Canada as a global leader in architecture and design.
To: Global Affairs Canada
Trade Negotiations- North America via
email: CUSMA-Consultations-ACEUM@international.gc.ca
From: Royal Architectural Institute of Canada (RAIC)
Re: Submission on the Operation of CUSMA and its Impact on Architecture
Executive Summary
CUSMA exists to enhance trade and professional mobility across North America by reducing barriers, ensuring transparency, and fostering cooperation. For architecture, this includes enabling cross-border professional services, supporting fair and transparent procurement, and aligning with shared continental priorities such as sustainability, innovation, and inclusive growth.
The RAIC recommends that Canada work with its CUSMA partners to:
1. Strengthen Professional Mobility: Recognize and promote the updated Tri-National Mutual Recognition Agreement (MRA).
2. Advance Fair Procurement: Encourage adoption of quality-based selection (QBS) and fair fee practices.
3. Integrate Climate Action: Use CUSMA’s environment and cooperation frameworks to promote building decarbonization and resilience.
4. Support Inclusive Trade: Reduce compliance burdens for small and medium-sized enterprises (SMEs) and support under-represented practitioners.
5. Uphold Indigenous Rights: Protect Indigenous procurement and design leadership under treaty provisions.
These recommendations support the core objectives of CUSMA: reducing barriers to trade in services, facilitating transparent and fair competition, and strengthening cooperation among the three countries.
CUSMA’s success in the architectural sector should not be measured solely by market access, but by how it supports design excellence and a culture of design across the built environment in all three countries. By promoting fair procurement and reciprocal mobility, the agreement can enhance innovation, cultural expression, and design quality, strengthening a North American culture of design that benefits communities and economies alike.
1. Professional Mobility and the Tri-National MRA
The 2024 Tri-National MRA between Canada, Mexico, and the U.S. modernizes reciprocal licensure by reducing the required post-licensure experience from ten years to five, removing citizenship restrictions, and expanding eligibility to include architects who earned licensure through alternative pathways. This expanded eligibility allows more architects to benefit from reciprocal recognition while maintaining public protection standards common to all three jurisdictions. It operationalizes CUSMA’s Chapter 15 provisions on professional services and Annex 15-C.
Recommendation:
- Highlight the MRA in CUSMA implementation reporting.
- Ensure border and regulator guidance is consistent and clear.
- Establish a trilateral architecture services cooperation stream to monitor uptake.
CUSMA’s procurement chapter does not apply to Canada–U.S. trade (which is covered under the WTO Government Procurement Agreement), it provides a valuable forum for cooperation and sharing of best practices.
Quality-Based Selection (QBS) ensures fair competition, design excellence, and lifecycle value. This aligns with CUSMA’s goal of transparent and efficient trade in services. QBS is both a transparent and fiscally responsible method of procurement. By prioritizing quality and competence in selection, public authorities enable consultants to define appropriate scope and design solutions early in the process, resulting in fewer change orders, fewer delays, and reduced construction risk. Investing appropriately in design and documentation phases consistently saves significant hard costs, delivering better project performance, higher value, and stronger design outcomes.
CUSMA can reinforce these shared standards of excellence by encouraging their adoption across all three nations. Embedding QBS principles within CUSMA cooperation would demonstrate Canada’s leadership in advancing both fiscal responsibility and design quality across North America.
Recommendation:
- Develop a trilateral QBS guideline for design services.
- Collect and share data on outcomes of QBS procurement models.
CUSMA’s environment chapter strengthens cooperation but does not explicitly reference climate change. Buildings and infrastructure are central to North American trade, competitiveness, and sustainability. Integrating environmental performance with design quality ensures that climate action in the built environment also strengthens cultural identity, livability, and architectural innovation across North America.
Recommendation:
Create a trilateral cooperation stream on low-carbon, resilient buildings.
Integrate life-cycle performance criteria into procurement under CUSMA cooperation forums.
Demonstrate a shared global ambition for climate leadership while empowering local innovation to achieve it.
4. Inclusive Trade and SME Access CUSMA emphasizes SME participation and reducing barriers. In architecture, SMEs and under-represented firms face disproportionate compliance burdens.
Recommendation:
- Recognize and promote the expertise, innovation capacity, and efficiency of architectural SMEs, whose contributions are critical to the design quality of the built environment across North America.
- Simplify pre-qualification and compliance requirements.
- Develop model templates and track equity, diversity, and inclusion (EDI) outcomes in professional services cooperation.
Article 32.5 and Canada’s Annex II reservations safeguard Indigenous rights and procurement preferences. Architecture plays a key role in Indigenous procurement and design leadership. Indigenous-led architectural practices exemplify design excellence rooted in cultural knowledge and stewardship, demonstrating how reconciliation contributes to a more holistic and sustainable North American design culture. These measures align with CUSMA’s objectives of fair competition and inclusive trade while recognizing the unique rights and contributions of Indigenous peoples.
Recommendation:
- Issue federal guidance affirming compatibility of Indigenous procurement policies with CUSMA.
- Promote Indigenous-led architectural services within CUSMA cooperation on inclusive trade.
Recommendation:
- Include architecture as a case study in Canada’s CUSMA implementation reports.
- Report annually on professional mobility, procurement practices, climate integration, and inclusion outcomes.
About the RAIC
The Royal Architectural Institute of Canada (RAIC) is a not-for-profit, national organization dedicated to representing architects and architecture since 1907. The RAIC is the only national voice for excellence in the built environment in Canada focused on providing Canada’s architects and architectural community with the tools, resources, and education to elevate their practice. The RAIC is committed to showcasing how design enhances quality of life, while advocating for important issues of society through responsible architecture. The RAIC’s mission is to build a better world for all by empowering a strong culture of design excellence in Canada. Through its work, the organization's vision is to establish Canada as a global leader in architecture and design.